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2022 (12) TMI 739

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..... order dated 25.06.2019 passed by the Ld. CIT(Appeals)-7, Ahmedabad for A.Y. 2011-12. 2. The grounds of appeal raised by the assessee read as under: "1. That the ld.AO has erred in law and facts by issuing notice under section 148 of the Act and further the ld.AO has erred in law by passing the order under section 143(3) r.w.s. 147 of the Act and therefore the ld. AO should be directed to accep .....

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..... ore, the then ITO issued a query letter to the assessee on 30.07.2013 and requested to submit the copy of return of income filed for A.Y. 2011-12 with computation of total income, supporting bank account statement, source of cash deposit with documentary evidences etc. In response, the assessee filed reply along with return of income and Form 16 only. The Assessing Officer made addition of Rs. 12, .....

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..... aged from his personal savings. The Ld. AR submitted that the details of which are set out in para 3 of the order of the CIT(A) where the assessee's submissions were quoted. Therefore, the Ld. AR prayed that the addition be deleted as the cash deposits were fully explained by the assessee before both the revenue authorities. 6. The Ld. DR relied upon the assessment order and the order of the CIT( .....

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..... in Government Hospital since 1976 and received salary, therefore, personal saving of a government employee cannot be doubted for several years. Thus, the Assessing Officer as well as the CIT(A) both failed to take cognizance of the evidences produced by the assessee during the assessment proceedings as well as before the CIT(A). The appeal of the assessee is allowed. 8. In result, appeal of the .....

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