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2025 (4) TMI 903

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..... d U/s. 143(3) r.w.s 147 of the Income Tax Act, 1961 ("the Act"). 2. Brief facts of the case are that the assessee is an individual deriving income from purchase and sale of prawn and fish business has not filed his return of income for the AY 2013-14. Accordingly, notice U/s. 148 of the Act dated 30/06/2016 was issued to the assessee and served on 6/7/2016. In response to the notice U/s. 148 of the Act, the assessee filed his return of income on 20/06/2017 admitting a total income at Rs. 1,97,680/-. Subsequently, the case was selected for scrutiny under manual category and a notice U/s. 142(1) of the Act dated 09/01/2017 was issued to the assessee and served on 02/02/2017. Based on the information available with the Department, it was noti .....

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..... 0,000/-. Aggrieved by the order of the Ld. AO, the assessee preferred an appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee contested that an amount of Rs. 8 lakhs is self-transfer from the assessee's same account held with Axis Bank. He therefore pleaded before the Ld. AO that the addition made for Rs. 53,50,000/- is not correct and shall be restricted only to 45,50,000/- [Rs. 53,50,000 - Rs. 8,00,000]. Further, the assessee reiterated the submissions made before the Ld. AO with respect to the cash deposits made by the assessee into the bank account. However, the Ld. CIT(A) did not accept the submissions made by the assessee thereby dismissing the appeal of the assessee. On being aggrieved by the order of the Ld. CIT(A), the .....

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..... l available on record as well as the orders of the Ld. Revenue Authorities. It is an admitted fact that the Ld. AO has acknowledged the fact that the assessee did not maintain any books of fact and neither produced any bills or vouchers for the purchase of packing material and Ice. Further, the Ld. AO also has also accepted the income from salary declared by the assessee and does not raise any doubts on the salary income but has observed that the assessee has scooped himself to such level to state that the cash deposits are raised due to sale of land and later contradicts his own statement that it has arisen out of the commission income received. From the submissions made by the Ld. AR, the only contention of the assessee is that the additi .....

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