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TMI Blog2022 (2) TMI 487X X X X Extracts X X X X X X X X Extracts X X X X ..... nd 2004-05 declaring income from sale of plots. There is nothing on record to suggest that her income was disturbed in any manner by the AO or it was not genuinely declared. Out of the sale proceeds of the plots, she transferred 19.69 lakhs to her father through banking channel on various dates, including three transactions in the year 2002 and five transactions in the year 2004 as have been set out on page 3 of assessment order. It was out of such deposits in the bank account of Shri Virendra Khilare, that he gave back 13 lakhs to his daughter in the year 2004 itself. A sum of 12,97,600 was deposited in the joint savings bank account out of this amount. Immediately after the deposit of the amount, the same was transferred to his wife s acc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,600 in his savings bank account maintained jointly with his wife in ICICI Bank. A notice u/s. 148 of the Act was issued. During the course of the reassessment proceedings, the assessee was called upon to explain the source of such deposits, to which it was stated that he was not carrying on any business and the only source of his income was salary. He further clarified that the deposit was in a joint bank account with his wife, Mrs. Navina R. Patil, who was separately assessed to tax. Copies of her returns of income along with PAN were also filed before the AO. The assessee further submitted that his wife received land at Kolhapur road, Sangli by way of a gift from her father, late Shri Virendra Khilare. This land was converted into plots ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... heard both the sides in Virtual Court and gone through the relevant material on record. The only dispute is about the source of deposit of cash of ₹ 12,97,600 in a joint bank account maintained by the assessee with his wife in ICICI Bank. Here it is relevant to mention that the assessee repeatedly stated before the AO that his only source of income was salary and no business was carried on. In support of the source of deposits, the assessee submitted that Shri Virendra Khilare, late father of his wife gifted certain land to the assessee. Copy of the gift deed was also made available. Wife of the assessee sold the land in plots. She filed her returns for the A.Ys. 2002-03, 2003-04 and 2004-05 declaring income from sale of plots. There ..... X X X X Extracts X X X X X X X X Extracts X X X X
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