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TMI Blog2021 (2) TMI 1032X X X X Extracts X X X X X X X X Extracts X X X X ..... would have been deposited in installments in bank account of the assessee. The entire circumstances would lead to irresistible conclusion that when assessee was caught by the Revenue authorities to explain the cash deposits in his bank account, assessee made a frivolous claim of the alleged amount received from Shri P.S. Narayana for getting insurance policies. It is also a fact that no evidence has been produced before the authorities below of the source of the cash deposited in the bank account of the assessee. No creditworthiness of Shri P.S. Narayana is also established through any evidence of giving any cash to the assessee on different occasions as alleged in the letter of Shri P.S. Narayana. Totality of the facts and circumstances, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y satisfactory explanation or evidence, therefore, AO made addition of ₹ 20,87,000/- to the income of the assessee u/s. 69 of the Act. 3. The assessee challenged the addition before Ld. CIT(A) and it was submitted that cash was deposited on behalf of his client Shri P.S. Narayana for Life Insurance Premium. It was submitted that insurance receipts were in the name of Ms. Pooja Narayana. The assessee filed statement of Shri P.S. Narayana dated 02.11.2017 in which it was explained that he has given cash totaling to ₹ 21 lakhs to the assessee on different occasions during the period from 2006 to 2010 as he planned to move out of India and settled abroad in 2010. He has requested the assessee to invest this amount into ICICI Life ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mounts. The AO on perusal of the premium receipts also noted that these receipts do not pertain to Shri P.S. Narayana from whom assessee claimed to have received cash amounting to ₹ 20.30 lakhs. It may also be noted that the letter of Shri P.S. Narayana dated 02.11.2017 explained that Shri P.S. Narayana has given cash amount of ₹ 21 lakhs to the assessee on different occasions during the period from 2006 to 2010. The assessee has also placed on record statement signed by assessee explaining therein that assessee had deposited cash into his bank account and made a demand draft in favour of the ICICI Prudential Life Insurance Company. The assessee stated in this letter that he has received cash amount of ₹ 8,30,000/- on 09.0 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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