2025 (4) TMI 2193

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.... Sudhir Sehgal (Adv) - Ld. AR For the Respondent : Smt. Kusum Bansal (CIT) - Ld. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid cross-appeals for Assessment Year (AY) 2019-20 arises out of an order of learned Commissioner of Income Tax (Appeals)-5, Ludhiana [CIT(A)] dated 02-06-2023 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s. 143(3) r.w.s. 1....

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....aled that the cash was received for Rs. 228.76 Lacs whereas cash was paid for Rs. 317.63 Lacs. The Ld. AO added entire amount of Rs. 317.63 Lacs u/s 69A. The Ld. CIT(A), considering the presumption of Sec.292C, observed that there was regular receipt and payment in cash. Therefore, the addition was to be made on the basis of peak credit. The same worked out to be Rs. 95.92 Lacs and accordingly, th....