9911796707
TMI Blog2023 (2) TMI 111X X X X Extracts X X X X X X X X Extracts X X X X ..... The authorities below has failed to make any further enquiries and bring on records any other materials to prove the source of cash deposits from any other source. Consequently, we set aside the order of the ld. CIT(A) and direct the AO to delete the addition - The ground no.3 is consequently allowed. Deduction under Chapter VIA by ld CIT(A) - HELD THAT:- After hearing the rival parties and perusing the materials on records we are of the view that the assessee is entitled to deduction under Chapter VIA of the Act but subject to verification by the AO. Accordingly the AO is directed to examine the issue and allow the deduction to the assessee. The ground no. 4 is also allowed in terms of our aforesaid direction. Appeal of the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ash deposited into the bank account by the assesse during demonetisation period. 3.1. The facts in brief are that the ITS data revealed that during the financial year 2016-17, the assessee has deposited cash to the tune of Rs.29,13,398/- into two bank accounts, namely, HDFC Bank Ltd. A/C No. 50100011637756 , Sector 46, Chandigarh Rs. Rs.2,50,000/- and Union Bank of India , Dhanbad A/C No. 469401010201028 of Rs.26,63,398/- , during the demonetisation period commencing from 09/11/2016 to 30/12/2016. Accordingly, a notice u/s 142(1)(i) of the Act was issued on 30/11/2017 and duly served upon the assessee. The assessee did not file any return of income, within the stipulated period and thus, the notice remained noncomplied with. The cases ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tices positively by 12/09/2019 and the assessee on 19/09/2019 uploaded submissions along with some documents. Similarly, the information was called for in respect of account maintained with the HDFC Bank and the assessee filed the reply in compliance. The assessee submitted before the Assessing Officer that he has received these cash payments upon sale of property which were deposited into the bank accounts. The reply of the assessee did not find favour with the Assessing Officer and finally an addition of Rs.23,17,541/- was made u/s 69A of the Act on account of cash deposits during demonetisation period which could not be explained by the assessee, in the assessment framed u/s 144 of the Act dated 28.12.2019. 3.2. In the appellate proce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pinder Singh Liddar, son of Sohan Singh Liddar and Smt. Kaulwant Kaur Lidder, resident of High Cables Hotlines Horpenden Hartford Share U.K., zip ak15- 2dy, United Kingdom, was the purchasers. We have gone through the contents of the agreement to sell and found that the assessee has received consideration on various dates by cheques as well as in cash which has been substantiated and testified with the said agreement to sell. Under these circumstances, we are not in a position to subscribe to the views of both the lower authorities as there is sufficient source of cash deposits into the bank accounts of the assessee. Besides , the authorities below has failed to make any further enquiries and bring on records any other materials to prove th ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
