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2023 (7) TMI 652 - ITAT DELHIReopening of assessment u/s 147 - Reasons to believe - cash deposited unexplained - HELD THAT:- No merit in the contention of the assessee that the reopening is illegal and is not based upon the reasons recorded by the Assessing Authority. Undisputedly, additions are made on the basis of cash deposited by the assessee and the assessee has failed to point out where the AO did not consider the facts available at the time of reopening of the assessment. Therefore, ground of the assessee’s appeal are dismissed. Addition of unexplained cash deposits - The assessee also filed affidavit of said Shri Duli Chand wherein he has admitted that he had received Rs. 15 lakh as advance in lieu of agreement to sell his land which he had given to the assessee for purchase of land. The stand of the assessee is that the sum received from Shri Duli Chand for propose sale of land was deposited by him in his bank account and since the deal could not be materialized the same was returned back to Shri Duli Chand - the averments made in the affidavit of Shri Duli Chand could not be rebutted by the Revenue - Decided in favour of assessee.
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