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TMI Blog2022 (1) TMI 371X X X X Extracts X X X X X X X X Extracts X X X X ..... ed to explain the source of deposits as advance received towards sale of land from Mr. Dharumbre and M/s. Prayas Buildwell Pvt. Ltd. and the cash deposits are stated to be made out of opening balance and withdrawal of the cash from the bank - before the ld. CIT(A) no confirmations from the parties from whom advance was received was filed and similarly the proof as to the existence of opening cash ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unds of appeal :- The following grounds are taken without prejudice to each other- On facts and in law - 1. The learned CIT(A) erred in confirming the addition of ₹ 1,79,57,720/- u/s 69 of the I. T. Act, 1961. For this and such other grounds as may be urged at the time of hearing, the order of the CIT (Appeals) and the Assessing Officer may be vacated and the appellant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,720/-, formed an opinion that the income escaped assessment and, accordingly, issued notice u/s 148 of the Income Tax Act, 1961 ( the Act ) on 14.03.2014. In response to the said notice u/s 148, no return of income was filed by the assessee. Subsequently, there was no response even to the notices issued u/s 142(1) by the Assessing Officer. In these circumstances, the Assessing Officer was constra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ontentions were rejected by the ld. CIT(A) for the reasons given in para 5.3.1 to 5.3.3 of his order. However, the ld. CIT(A) had remitted the issue of availability of opening balance of ₹ 3,34,142/- to Assessing Officer. 6. Being aggrieved by the decision of the ld. CIT(A), the appellant is before us in the present appeal. 7. Even before us, when the appeal was called on none appeared ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... led and similarly the proof as to the existence of opening cash balance as well as cash withdrawn from bank was not filed. In the circumstances, the ld. CIT(A) was justified in rejecting the explanation offered in support of the credits appearing in the bank account of the assessee. Accordingly, we uphold the order of the ld. CIT(A). We do not find merit in the appeal filed by the assessee. Thus, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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