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TMI Blog2017 (12) TMI 1137X X X X Extracts X X X X X X X X Extracts X X X X ..... me to reconcile the books to explain the source of cash. The recording of assessee’s statement was resumed on 30.04.2011. On the said date, assessee admitted that ₹ 5,00,000/- is his unaccounted income for the assessment year 2012-13 on account of unexplained cash. Thus, assessee had ample time at least to make out whether this amount of ₹ 5,00,000/- belongs to the firm or on his personal account. CIT(Appeals) rightly pointed that the assessee never claimed while recording statement that cash belongs to the firm. We concur with the view of lower authorities that attributing ₹ 5,00,000/- as cash of the firm is an afterthought. - Decided against assessee. - ITA No. 17 /PUN/2016 - - - Dated:- 6-10-2017 - SHRI ANIL CHAT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... offer the aforesaid amount of ₹ 5,00,000/- to tax. During assessment proceedings, the assessee submitted that after completion of books and reconciliation, it was found that the said cash belongs to the firm M/s. Surekh Jewellers and hence, the same was not offered to tax in the hands of the assessee. The Assessing Officer was not convinced with the explanation furnished by the assessee and made addition of ₹ 5,00,000/- in the income returned by the assessee. Aggrieved with the assessment order dated 27.02.2014, the assessee filed appeal before the Commissioner of Income Tax(Appeals) and reiterated the submissions made before Assessing Officer. The Commissioner of Income Tax (Appeals) also rejected the contention of assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Assistant Commissioner of Income Tax, 151 ITD 224 ( Pune ) ii ) Jyotichand Bhaichand Saraf Songs ( P .) Ltd . Vs . Deputy Commissioner of Income Tax, 139 ITD 10 ( Pune ) iii ) Chawla Brothers ( P .) Ltd . Vs . Assistant Commissioner of Income tax, 43 SOT 651 ( Mumbai ) 5. On the other hand, Smt. Sumitra Banerjee representing the Department vehemently defended the impugned order. The ld. DR submitted that the assessee in his statement recorded on oath admitted that ₹ 5,00,000/- is his unaccounted income for the assessment year 2012-13. Nowhere in his statement during search, the assessee has ever claimed that ₹ 5,00,000/- belongs to the firm and not to the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X
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