TaxTMI 
2026 (11) TMI 474
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....lation of Principle of Natural Justice :- 1.1. The Ld. CIT (Appeals) has erred in law as well as facts by sustaining the addition of Rs. 2,49,000/- as an unexplained cash credit u/s. 68 of Income Tax Act 1961. 1.2. The CIT (Appeals) passed the order without providing proper and effective opportunity of being heard without issuing show cause notice in respect of addition and without giving opportunity of personal hearing through video conferencing as mandated under section 144B of the Act. 1.3. The order passed by Ld. CIT (Appeals) is in violation of natural justice and therefore liable to be quashed. 2. Addition u/s. 68 of Rs. 2,49,000/- Unexplained Cash Credit :- 2.1. The Ld. CIT (Appeals) erred....
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....e receipt treated as unexplained cash credit u/s. 68 of Income Tax Act 1961. 5. Prayer :- 5.1. The appellant crave, add, alter, amend any ground at the time of hearing 5.2. The addition of Rs. 2,49,000/- confirmed by the Ld. CIT(Appeals) be deleted. 5.3. Any other relief deemed fit in the interest of natural justice may kindly be granted." 3. The assessee, an individual running proprietorship M/s Raj Novelty Stores engaged in money-transfer activity, filed his return of income for AY 2022-23 on 13.07.2022 declaring total income of Rs. 2,57,720/- after Chapter VI-A deductions. The case was selected for scrutiny due to high-value cash deposits of Rs. 6,49,66,860/- reported in SFT-003/004 vis-à-vis....
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....e the CIT(A). The CIT(A) partly allowed the appeal of the assessee. 5. As regards Ground No.1 (1.1, 1.2, 1.3), the same are dismissed as the assessee was given proper opportunity. 6. As regards Grounds No.3 (3.1, 3.2), 4 & 5, the same are not required to be adjudicated as we are adjudicating the issues on merit. Hence, Gr. Nos. 3 (3.1, 3.2) & 4, 5 are dismissed. 7. As regards Grounds Nos. 2 (2.1, 2.2, 2.3 & 2.4), the Ld. Authorised Representative (in short "Ld. AR") for the assessee submitted that the assessee has all the details of PAN No. of all the customers. In fact, the assessee is engaged in the business of money transfer and the cash received from various customers was in the normal course of business. All the transactions c....