9911796707
TMI Blog2024 (8) TMI 735X X X X Extracts X X X X X X X X Extracts X X X X ..... have been pumped into as unaccounted money. Instruction 21/02/2017 issued by the CBDT suggests some indicators towards verifying the suspicion of backdating of cash. It also suggests indicators to identify abnormal jump in cash trials on identifiable persons as compared to earlier history in the previous year. Therefore in our opinion it is important to examine whether assessee falls into any of these categories and transfer of deposit of cash is not in line with history of transactions in the preceding assessment years. Assessee is directed to establish all relevant details to substantiate its claim in line with the above applicable instructions based on the facts in present case. We are aware of the fact that not every deposit during the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... applied to the assessee. 5. Assessee prays leave to add any other grounds of appeal before or at the time of hearing. 2. Brief facts of the case are as under: 2.1 The assessee is an agriculturist. The assessee deposited a sum of Rs. 17,73,000/- in the form of cash in his bank account with Vijaya Bank, Gadag. The said amount was deposited out of previous drawings from bank. The ITO issued notice u/s. 143(2) on 28.09.2018. The ITO has completed the assessment by adding entire sum of Rs. 17,73,000/- deposit during demonetization period. The Ld.AO after considering the submissions, added Rs. 17,73,000/- as unexplained money. 2.2 Aggrieved by the order of the Ld.AO, assessee preferred appeal before the Ld.CIT(A) wherein it was submitted that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e purpose of assessing such cases. 7. In 1 of such instructions dated 09/08/2019 speaks about the comparative analysis of cash deposits, cash sales, month wise cash sales and cash deposits. It also provides that whether in such cases the books of accounts have been rejected or not where substantial evidences of vide variation be found between these statistical analyses. Therefore, it is very important to note that whether the case of the assessee falls into statistical analysis, which suggests that there is a booking of sales, which is non-existent and thereby unaccounted money of the assessee in old currency notes (SBN) have been pumped into as unaccounted money. 8. Instruction 21/02/2017 issued by the CBDT suggests some indicators towards ..... X X X X Extracts X X X X X X X X Extracts X X X X
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