TaxTMI 
TaxTMI 
2026 (9) TMI 2032
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....hich dismissed the appeal filed by the assessee against the reassessment order dated 28 April 2025 passed under section 147 of the Income Tax Act read with section 1443 of the Act by the assessment unit of the Income Tax Department, determining the total income of the assessee at Rs. 4,099,920. 2. The Assessee has raised the following grounds of appeal: 1. The order passed by the Learned Assessing Officer u/s 147 and confirmed by the First Appellate Authority is bad in law. 2. The Notice issued by the Income Tax Officer, Ward-1, Hassan u/s 148 on 24.03.2024 is not valid and without jurisdiction. 3. The Learned Assessing Officer and FAA have erred in making addition of Rs. 39,28,000/- u/s. 69A of the Act. ....
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....ry evidence, including details of the buyers of gold and silver. However, she did not provide the required evidence. The Assessing Officer also issued a notice under section 133(6) to the co- operative bank in which the sums were deposited. As the assessee failed to furnish concrete documentary evidence despite several notices, the Assessing Officer treated cash deposits of Rs. 39,28,000 in the co- operative bank and Karnataka Bank Limited as unexplained and also made an addition of Rs. 4, 678 towards bank interest. The Assessing Officer accordingly passed the assessment order on 28 February 2025, determining the assessee' s total income at Rs. 42,99,920. 4. Aggrieved, the assessee appealed to the learned CIT(A), who, by order dated ....
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.... He also referred to the affidavit of the assessee's father, confirmations from the purchasers, and stock details relating to the gold ornaments sold. In addition, he relied on details of the assessee's catering business to explain the cash deposits of Rs.17,30,000. 6. The learned departmental representative, Shri Sundeep Kumar H.S., Assistant Commissioner of Income Tax, strongly supported the orders of the lower authorities. He submitted that the authorities had rightly rejected the assessee's claim that she was engaged in a catering business or that the amounts received represented proceeds from the sale of ornaments to different persons. He further contended that, in the absence of supporting evidence, the assessee's explanation regar....
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....horities, they require verification in the interests of justice. The persons who issued the confirmations, the contents of the affidavits, and the assessee's complete computation of income need to be examined. The confirmations relating to the catering activity filed before us are also fresh evidence and must be verified. Further, where the assessee claims that cash deposits of Rs.17,30,000 arose from catering receipts, it is necessary to examine whether she in fact carried on such business, as the learned lower authorities have expressed doubt. Accordingly, the origin of the deposits, the expenses incurred, and the profit resulting therefrom must be examined. The burden is on the assessee to prove that she carried on the catering business,....