2026 (9) TMI 1878

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..../s 143(3) of Income-tax Act, 1961 ["the Act"] for Assessment-Year ["AY"] 2017-18, the assessee has filed this appeal. 2. The background facts leading to present appeal are such that the assessee-individual filed his return of income of AY 2017-18 declaring a total income of Rs. 5,58,150/-. The case of assessee was selected for scrutiny and the Ld. AO issued notices u/s 143(2)/142(1) which the assessee complied with. During assessment-proceeding, the Ld. AO questioned assessee qua the source of making cash deposit of Rs. 37,00,000/- in bank a/c during demonetization period. In response, the assessee explained these sources, namely (i) deposit from sale proceed of old car - Rs. 13,75,988/-, (ii) deposit from sale proceed of agriculture - R....

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....end or withdraw any of the grounds of appeal before hearing." Ground No. 1: 4. Ground No. 1 challenges the addition of Rs. 11,96,600/- upheld by Ld. CIT(A). After making some initiation submissions of the facts, Ld. AR for assessee made a straightforward limited prayer that the benefit of Para No. 1.1 of the Annexure to CBDT Instruction No. 3/2017 dated 21.02.2017 "Standard Operating Procedure (SOP) to be followed by the Assessing Officers in verification of Cash transactions relating to demonetization" may be allowed to the assessee. According to the said Para, in the case of an individual not having business income, no verification is required in respect of cash deposit upto Rs. 2.50 lakh. The Ld. AR further submitted in open court ....