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Issues involved:
Assessment of total income based on cash deposits as income from undisclosed sources for the assessment year 2011-12. Detailed Analysis: 1. The appellant filed an appeal against the order of the ld. Commissioner of Income Tax (Appeals) regarding the assessment year 2011-12, where the Assessing Officer assessed the total income at &8377;2,19,20,740/- by adding cash deposits of &8377;2,17,49,200/- as income from undisclosed sources. The ld. CIT(A) granted partial relief, sustaining &8377;91,34,664/- on estimate basis. 2. The appellant contended that the cash deposits were made to facilitate the sale of timber in a relative's business, receiving commission without having income to the extent assessed. The appellant provided bank statements and confirmation letters to support the claim. 3. The ld. CIT(A) observed that the appellant's submissions indicated a pattern where cheques were issued and discounted by recipients to generate cash flow, which was then returned to the appellant for deposit. However, the effective interest rate calculated was unreasonably high, raising doubts about the commercial viability of the transactions. 4. The Tribunal considered the evidence and adopted a different approach, reducing the estimated effective interest rate to 26% of the gross cash deposited. Consequently, &8377;56,54,792/- was sustained as income, granting relief of &8377;1,60,94,408/- to the appellant. 5. The Tribunal found the ld. CIT(A)'s estimation of the effective interest rate to be on the higher side, leading to a revised calculation and partial allowance of the appeal. 6. The judgment was pronounced on 18th November 2022 at Chennai, with the appeal being partly allowed.
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