TaxTMI 
TaxTMI 
2026 (10) TMI 270
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....A)'] whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 26/09/2019, passed under Section 144 of the Income Act, 1961 [hereinafter referred to as 'the Act'] for the Assessment Year 2017-2018. 2. The Assessee has raised the following grounds of appeal: 1. That, the Ld. CIT (A) has wrongly confirmed the addition of alleged unexplained invest u/s 69 of the Act of Rs. 10,72,000/-. 2. That, the Ld. CIT (A) has wrongly confirmed the addition of income from other sources being interest Income Rs. Rs. 1,39,021/- beyond income reported in Form 26AS. 3. That, the Ld. CIT (A) has wrongly confirmed application of provisions of section 115BBE of the I.T. Act, 1961. 4. That, the L....
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....1, received Form-2 from the Principal Commissioner of Income Tax on, and had deposited the full tax amount in good faith. However, in late September 2025, the Assessee received communication that Form-2 has been rejected. Being an NRI in the USA, the Assessee could not travel immediately, but planned his trip to India to file this appeal in late November 2025 and thereafter, the present appeal got filed in December 2025. Thus, we note that the Assessee was actively pursuing statutory dispute resolution under VSVS 2024 and had deposited the tax demand. The unexpected rejection of Form-2 led to filing of present appeal. Given the aforesaid applying the principles laid down by the Hon'ble Supreme Court in the case of Collector, Land Acquis....
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....urce of cash deposits was past savings. It was submitted that the Assessee and his family regularly remit funds earned abroad in the USA to India through authorized banking channels to meet personal expenses, household maintenance, and purchases. Any unspent cash brought during visits or converted from foreign exchange was held as accumulated capital savings. It has been contended that during the financial year 2016-17 alone, the Assessee remitted over INR.10,000,000/- through regular banking channels. We note that averments to this effect were made in the statement of facts filed before the Learned CIT(A). In compliance with the direction given during the course of hearing, the Learned Authorised Representative for the Assessee has placed ....