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TMI Blog2023 (7) TMI 798X X X X Extracts X X X X X X X X Extracts X X X X ..... that the amount collected and deposited in his bank account was not his income, but it was the amount collected for various services rendered and for depositing into the account of Govt. of Andhra Pradesh. We find force in the argument of the Ld.AR therefore set aside the order passed by the Ld.CIT(A) and allow the appeal of the assessee. - I.T.A.No. 101/Viz/2023 - - - Dated:- 17-7-2023 - Shri Duvvuru Rl Reddy, Hon ble Judicial Member For the Appellant : Shri G.V.N.Hari, AR For the Respondent : Shri O.N.Hari Prasada Rao, DR ORDER PER SHRI DUVVURU RL REDDY, JUDICIAL MEMBER : This appeal is filed by the assessee against the order of Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ertificate by APT online for the period 09.05.2018 to 08.05.2019. The AO held that the assessee cannot be held to be the owner of the agency for the A.Y. 2017-18, but observed from the bank statement filed by the assessee that some of the transactions appearing therein related to payments from the bank account. Thus, in view of the ambiguity noticed in the case of the ownership of the agency and taking into consideration, the case has been selected under CASS for examining the cash deposits, the AO estimated the income at 8% on the aggregate cash deposits / credits of Rs. 1,26,21,900/-, which works out to Rs. 10,09,752/- and the same was brought to tax. 3. Aggrieved by the order of the AO, the assessee preferred an appeal before the CIT( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e ownership of USDP VZLS Mee Seva during the impugned assessment year and the Ld.CIT(A) has correctly upheld the addition made by the AO. He, therefore, pleaded to uphold the order passed by the Ld.CIT(A) and dismiss the appeal of the assessee. 8. I have heard both the parties and perused the material available on record. It is undisputed fact that USDP VZLS Mee Seva was sold in favour of the assessee by Smt. Nainala Veera Veni on 19.04.2016 as evident from the paper book filed. I have gone through the APT online certificates, sale letter executed filed before the Ld.CIT(A) and the reply filed by the assessee in response to the notice issued and served u/s 143(2) of the Act by the department. On careful examination of the same, I find th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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