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TMI Blog2022 (12) TMI 220X X X X Extracts X X X X X X X X Extracts X X X X ..... lant by : None Respondent by : Shri P. Sajit Kumar, JCIT ORDER PER V. DURGA RAO , JUDICIAL MEMBER : This appeal filed by the assessee is directed against the order of the ld. Commissioner of Income Tax (Appeals) 6, Chennai dated 24.11.2017 relevant to the assessment year 2011-12. 2. Brief facts of the case are that the assessee filed his return of income for the assessment year 2011-12 on 14.09.2011 admitting total income of ₹.8,94,648/-. Subsequently, the case was selected for scrutiny through CASS and notice under section 143(2) of the Income Tax Act, 1961 was issued to the assessee on 31.07.2012. After considering the details furnished by the assessee against statutory notices and by following due procedure, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fficer. The remand report furnished by the Assessing Officer and the findings of the ld. CIT(A) are reproduced as under: 2. Vide the letter of your good self on the above subject, the undersigned has been directed to examine the additional evidences filed by the assessee during the course of appeal proceedings and directed to submit the remand report. The additional evidences submitted by the assessee are documents related to the source for cash deposits such as the ledger accounts jewel loan statement from Kumbakonam Mutual Fund Benefit Fund Ltd., etc. On perusal of the additional evidences, the following observations are made: Date Cash deposits Source ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tching between the dates of loan amount received and cash deposited. Further, the said pledged jewel loan along with interest was repaid on 08.01.2011 and 17.02.2011 for which source is not explained. Since, the source for jewels is already considered (unexplained and added) in the preceding para, telescoping is given. Therefore, the source is explained. 03.02.2011 98000 02.03.2011 70000 02.03.2011 70000 Jewel loan received on 31.01.2011 to the tune of ₹.1,60,000/-. Here, there is no reasonable matching between the dates of loan amount received and cash deposited. Therefore, the entire amount o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 03.12.2010 100000 15.12.2010 490000 There was cash withdrawn on 15.12.2010 to the tune of ₹.5,00,000/- from the bank account of the company M/s. Grahalaya Constructions Pvt. Ltd. It is considered as source as this amount is reflected in the books of company and in the assessee company. 3. A per the jewel loan statement, the total cost of jewellery pledged was about ₹.22,00,000/- which was re-pledged and shown as source for cash deposits. The source for the repayment of loan and interest also not explained. Therefore, an amount of ₹.29,61,000/- is to be added back as discussed above since the source for cash deposits are not ex ..... X X X X Extracts X X X X X X X X Extracts X X X X
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