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2023 (1) TMI 164

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..... at the source is explained and even the assessee s father confirmed having handed over the above sum of Rs.8 lakhs to his son, which ultimately got deposited in assessee s bank account on 10.11.2016. We find explanation of the assessee as reasonable and assessee could explain the source of this money and hence, the same cannot be treated as unexplained u/s.69A of the Act. Therefore, we delete this addition and allow the appeal of assessee. - ITA No.: 689/CHNY/2022 - - - Dated:- 21-12-2022 - Shri Mahavir Singh, Vice President And Shri Manoj Kumar Aggarwal, Accountant Member For the Appellant : Shri S. Sridhar, Advocate For the Respondent : Shri P. Sajit Kumar, JCIT ORDER PER MAHAVIR SINGH, VICE PRESIDENT: This a .....

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..... the AO or before the CIT(A) at the first instance and for not filing before the lower authorities, the assessee has no reasonable cause and there is no reason or occasion to file before Tribunal for the first time. He aggressively took his stand that this should not be admitted as additional evidence. 4. After hearing both the sides and going through the fact that the AO made total addition of Rs.26 lakhs as unexplained money u/s.69A of the Act being amount deposited during demonetization period in his bank account No.000901589886 maintained with ICICI bank. The CIT(A) accepted the explanation of the assessee receiving money from his wife to the extent of Rs.18 lakhs but denied the explanation of assessee receiving money from his father .....

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..... deposit in the account till March, 17, 2017. The cash deposited in assessee's account was at on go on 10.11.2016. But complete fact regarding assessee's father depositing cash in assessee's account is lacking. ń case of assessee's wife, Yashoda, the money got transferred to her accou t from that of assessee's bank account. Therefore, there is sufficient reason to believe that assessee's wife deposited the money to his account. This is not the case regarding assessee's father. It is not the case of assessee that he transferred money to his father for making FD. It is not understood as to how assessee's father allegedly deposited money into assessee's account when there are no proof that the money bel .....

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