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TMI Blog2024 (11) TMI 1389X X X X Extracts X X X X X X X X Extracts X X X X ..... d in cash. AO had passed the impugned order holding that the petitioner s response was found to be unsatisfactory. The entire purpose of issuing a notice u/s 148A (b) of the Act is to enable the Assessee to respond to the information available with the AO, which may be suggestive of the Assessee s income escaping assessment. In the instant case, where the allegation is that a large cash deposits were made in the bank account of the petitioner, the least that was required for the petitioner was to inform the AO as to the correct quantum of the cash deposits in his bank account and his explanation for the same. This crucial information is not available in the petitioner s response to the impugned notice. It is relevant to note that at the thr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g of the petitioner s assessment for the assessment year (AY) 2017-18. 5. Apart from assailing the impugned notice and the impugned order on merits, the petitioner also challenges the initiation of the said proceedings on the ground of jurisdiction of the Jurisdictional Assessing Officer (hereafter the JAO). The petitioner claims that JAO does not have the jurisdiction to initiate the said proceedings after the issuance of CBDT Notification dated 29.03.2022. 6. Insofar as the petitioner s challenge to the jurisdiction of the JAO to issue the impugned notice is concerned, the said issue stands settled in favour of the Revenue by the decision of this court in T.K.S. Builders Pvt. Ltd. v. Income Tax Officer Ward 25 (3) New Delhi, 2024:DHC:8330 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t person, in a financial year SBI CARDS AND PAYMENT SERVICES PRIVATE LIMITED Aggregate gross amount received from person in cash 5241312 SFT-006 Payments made by any person in respect of one or more credit cards issued to that person, in a financial year KOTAK MAHINDRA BANK LIMITED Aggregate gross amount received from person in cash 5921118 SFT-006 Payments made by any person in respect of one or more credit cards issued to that person, in a financial year THE SHANGHAI BANKING CORPORATION LTD HONGKONG Aggregate gross amount received from person in cash 1132729 SFT-005 Payments made by any person in respect of one or more credit cards issued to that person, in a financial year INDUSIND BANK LIMITED Aggregate gross amount received from person ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itioner had responded to the impugned notice raising several issues. However, we do not find that the said response contains any information either as to the quantum of cash deposited during the previous year relevant to the AY 2017-18. There was also no explanation as to why large amounts were received in cash. 11. In view of the above, the AO had passed the impugned order holding that the petitioner s response was found to be unsatisfactory. 12. The entire purpose of issuing a notice under Section 148A (b) of the Act is to enable the Assessee to respond to the information available with the AO, which may be suggestive of the Assessee s income escaping assessment. In the instant case, where the allegation is that a large cash deposits were ..... X X X X Extracts X X X X X X X X Extracts X X X X
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