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TMI Blog2022 (5) TMI 276X X X X Extracts X X X X X X X X Extracts X X X X ..... 0,000/- was credited through account payee cheque on 12.06.2014 and Rs. 30,000/- deposited in cash in the bank on 12.06.2014. Further, in the case of Smt. Shalika Singhal, it was stated that a sum of Rs. 30,000/- was received as a professional income in cash which was deposited out of the professional income. It is seen that the authorities below have not commented and made any inquiry on this explanation of the assessee. We find that there is a categorical submission by the assessee that in the case of lenders HUF, the amount was deposited through account payee cheque which was recorded as cash deposits by the assessing authority. Therefore, under these facts, additions made and sustained by the authorities below was in a mechanical manner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the sustaining of addition of Rs. 5,70,000/-. FACTS OF THE CASE 3. Facts giving rise to the present appeal are that in this case, the assessee filed its return of income on 25.09.2015 declaring an income of Rs. 62,970/-. The case was selected for scrutiny assessment and the assessment u/s. 143(3) of the Income Tax Act, 1961 ( the Act ) was framed vide order dated 26.12.2017. During the assessment proceedings, the Assessing Officer ( AO ) noticed that from perusal of the audit report, the assessee had claimed to have obtained unsecured loans either from Directors or relatives of such Directors of the assessee company namely, Shri Shailesh Kumar Singhal of Rs. 13,58,000/-; Smt. Seema Singhal of Rs. 10,30,000/-; M/s. S.K. Singhal (HUF) o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ghal, there was certain cash deposits on 02.04.2014 and only a sum of Rs. 1,00,000/- was given to the assessee company and again on 12.06.2014, there were cash deposit of Rs. 20,000/- and the same amount was given to the assessee company. Further, on 20.12.2014, a sum of Rs. 30,000/- was deposited and a sum of Rs. 30,000/- was given to the assessee company. In respect of M/s. S.K. Singhal (HUF), a sum of Rs. 3,00,000/- was deposited on 31.03.2014 by cash and on 04.04.2014, the same amount was given to the assessee company. On 12.06.2014, an amount of Rs. 30,000/- was deposited and same amount given to the assessee company. Similarly, on 20.12.2014 11.03.2015, amount of Rs. 20,000/- and Rs. 25,000/- was deposited and same amounts were give ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... during the course of appellate proceedings appellant failed to rebut the observation of the AO wherein the submissions of the three lenders i.e. Smt. Shalika Singhal, Shailesh Kumar Singhal (HuF) and Smt. Seema Singhal are given on page 2 of the assessment order which is scanned as under: Based on these facts vide order sheet entry dated 11.12.2017, the assessee was questioned to explain that there are cash deposits in the bank accounts of the persons who have given unsecured loans to assessee company just a day before or on the date the loan has been given to assessee otherwise the balance in bank accounts of unsecured loaners is very meager whole of the year around. Vide reply dated 20.12.2014 the assessee through its counsel submit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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