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2019 (5) TMI 1556 - PUNJAB AND HARYANA HIGH COURTAddition u/s 69 - Unexplained investments - unexplained cash found deposited in the bank account of the assessee - as per CIT-A making cash withdrawals at one point of time cannot be a sole basis for explaining the cash deposit in future - HELD THAT:- When the assessee was asked to explain, she stated that the same was attributable to her opening cash in hand and furnished a copy of cash book for the relevant financial year showing opening balance of ₹ 22,50,000/-. The assessee was asked to justify the opening balance to which it was submitted that the cash in hand to the tune of ₹ 20 lacs was on account of cash withdrawn by her in the preceding year in June 2012 for the purpose of investment which was not made due to lack of investment and thus remained as such with her. The Assessing Officer noticed that the assessee had raised loans and also withdrawn cash numerous times thereafter which was not needed, if she already had so much cash in hand and had deposited cash in three installments after a period of 8-9 months. The Assessing Officer not accepting her explanation made the addition of ₹ 20,79,000/- on account of unexplained deposits, to the returned income of the assessee. The CIT(A) in appeal held that the circumstances showed that the withdrawal attributed by the assessee to the opening cash in hand was not actually available with her so as to justify the cash deposited. The Tribunal upheld the findings recorded by the Assessing Officer and the CIT(A). The concurrent findings of fact recorded by the authorities below have not been shown to be illegal or perverse by the learned counsel for the appellant-assessee warranting interference by this Court. No substantial question of law arises.
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