9911796707
TMI Blog2024 (1) TMI 110X X X X Extracts X X X X X X X X Extracts X X X X ..... ash withdrawals on 24.11.2016 from the same bank account amounting to Rs. 50,000/- which sum is definitely available as a source for explaining cash deposits. Hence, to this extent the assessee would be automatically eligible for credit. With regard to the remaining sum of Rs. 45,000/- of cash deposits, as stated earlier, we find that assessee had duly offered the other income of Rs. 6.78 lakhs earned in cash, which itself explains the source for making cash deposit of Rs. 45,000/-. Hence, we hold that the entire cash deposits of Rs. 95,000/- stands duly explained by the assessee and the there is no scope for making any addition. Interest u/s 234B which is consequential in nature and does not require any specific adjudication. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ntion of the assessee that the order passed by the learned AO under section 153A r.w.s 143(3) is illegal and bad in law as the same has been passed without having valid jurisdiction. 4. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in rejecting the contention of the assessee that the order passed by the AO under section 153A r.w.s. 143(3) is bad and liable to be quashed as the same has been framed consequent to the search which was initiated under the wrong pretext. 5. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in rejecting the contention of the assessee that the order passed by the learned AO under section 153A r.w.s 143 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aw as the same was issued prior to the issue of notice under section 14362) of the Act (ii) That the learned CIT(A) has erred, both on facts and in law, in confirming the action of the learned AO in drawing adverse inference against the appellant on the basis of above notice issued under section 142(1) of the Act which itself is invalid 10. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in rejecting the contention of the assessee that the learned AO has erred in making the addition in order passed u/s 153A r.w.s 143(3) of the Act, without any incriminating material having been found during the course of search. 11. (i) On the facts and circumstances of the case, the learned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing the above addition by indulging in surmises without bringing on any direct evidence against the assessee, only on the basis of presumption and assumption. 15. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in confirming the action of the AO in wrongly charging interest under section 234B and section 234C of the Income Tax Act. 16. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in confirming the action of the AO in determining the tax liability as per section 115BBE of the Act. 17. That the appellant craves leave to add, amend or alter any of the grounds of appeal. 3. Grounds numbers 1 to 12 raised by the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X
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