9911796707
TMI Blog2025 (1) TMI 322X X X X Extracts X X X X X X X X Extracts X X X X ..... d to be the income of the assessee for such year. In the present case, assessee has purchased the credit cards by making cash payments. It is, therefore, clear that assessee was owner of money (cash) which was used to make credit card purchases. However, he has not explained the nature and source of acquisition of such money, being cash - AO has added the same u/s 69A of the Act due to non-compliance by assessee to the statutory notices as well as the show cause notice. CIT(A) has rightly confirmed the addition because assessee did not attend before him or filed any written submission in support of the grounds raised before him. Before us also, the assessee has not filed any written submission in support of the grounds raised by him. Provis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1.2017, declaring total income at Rs. 2,78,400/-. The assessee had made cash payment towards credit card purchases of Rs. 6,16,142/-. The Assessing Officer (in short, AO ) asked the assessee to explain the source of the above cash payments. The AO also issued show cause notice which was not replied to by the assessee. Therefore, the AO held that the amount of cash payment of Rs. 6,16,000/- remained unexplained and constitutes income of the assessee u/s 69A of the Act. He also held that tax on this income will be charged u/s 115BBE of the Act. 5. Aggrieved by the order of AO, the assessee filed appeal before the CIT(A). The CIT(A) issued 7 notices as per the details at para 4 of the appellate order. There was no response of the assessee to a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee attended before us nor any written submission was filed in support of the grounds raised in the appeal. It may be stated that there is only one effective ground i.e., addition of Rs. 6,16,142/- u/s 69A of the Act. On the other hand, Learned Senior Departmental Representative of the revenue supported the orders of lower authorities. The assessee had made cash payments for credit card purchases i.e., Rs. 3,37,650/- with RBL Bank Ltd., Rs. 1,66,492/- with SBI Cards and Payment Services Pvt. Ltd. and Rs. 1,12,000/- with City Bank. Both AO and CIT(A) issued several notices but assessee chose not to respond to the notices nor file any written submission. Provisions of section 69A of the Act are clear. Where the assessee is found be the ow ..... X X X X Extracts X X X X X X X X Extracts X X X X
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