TMI Blog2014 (7) TMI 856X X X X Extracts X X X X X X X X Extracts X X X X ..... s of the coaching centre and the preponderance of human behaviour read with all the evidences establishes this fact in favour of the assessee - assessee being in Australia during the period when assessment proceedings were going on, he was prevented by sufficient cause in producing all the evidences before the AO and the additional evidences were accepted under Rule 46A - amount of opening balance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Revenue. He submitted that there were cash deposits in the bank account of the assessee and the same could not be explained satisfactorily by the assessee and the addition was rightly made in the hands of the assessee. He relied on the order of the Assessing Officer. 4. The assessee has appeared in person and has filed the written submission in support of his case. He has basically reli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ut by the students outside India established that the amounts were issued in favour of the students. The CIT(A) has further observed that considering that none of the students was closely related to the assessee, under no circumstances such payments could be even considered gifts made by the assessee. The CIT(A) has upheld the claim of the assessee that the assessee has allowed his bank account to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a balanced and speaking order after considering all the evidences brought on record, we hold that no interference in the order of CIT(A) is called for which is accordingly confirmed and the ground of appeal of the Revenue is dismissed. 6. In the result, the appeal of the Revenue is dismissed. Order pronounced in the Court on Friday, the 06th of June, 2014 at Ahmedabad. - - TaxTMI - TMIT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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