9911796707
TMI Blog2025 (1) TMI 1399X X X X Extracts X X X X X X X X Extracts X X X X ..... planation is taken into consideration, based on cumulative circumstances, namely; (1) Rs. 10 lacs was declared to cover up such type of issues in the case of M/s Avinash Agro Pvt. Ltd.; (b) Past savings of the family members, and (c) Gift received from the brothers, then it would be established that source of cash is available with the assessee. It is difficult to establish a cash available in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mmissioner of Income Tax (Appeals) [in short 'the CIT (A)'] dated 17.06.2022 passed for assessment year 2019-20. Though the assessee has taken five grounds of appeal but his solitary grievance is that ld. CIT(A) has erred in confirming the addition of Rs. 6 lacs which was added by the Assessing Officer on account of unexplained cash found at the residential premises during the course of search. 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income Tax Act. The Question No. 12 exhibits that how much cash is lying within his residential premises. In reply to it, it was submitted by the assessee that approximately Rs. 10.50 lacs is available. Similarly, when it was put to the assessee that whether this cash belongs to somebody else, then assessee has replied that this cash related to him, his business concern and may be of family m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tinent to note that during the course of search, assessee in the capacity of one of the Director has declared a sum of Rs. 10 lacs in M/s Avinash Agro Pvt. Ltd. to cover up any irregularity in explanation of any unexplained item. This Rs. 10 lacs has been assessed in the hands of M/s Avinash Agro Pvt. Ltd. which was framed under Section 143(3) of the Income Tax Act. The ld. Counsel for the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ematic precision. It is to be appreciated on the normal human behaviour available in the family and if all the family members are assessable to tax, then possibility of their savings and availability of Rs. 10 lacs could never be denied. Therefore, learned Revenue Officers have erred in not appreciating the facts and circumstances in right perspective and confirming the addition of Rs. 6 lacs. We ..... X X X X Extracts X X X X X X X X Extracts X X X X
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