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2020 (5) TMI 543 - AT - Income TaxReopening of assessment u/s 147 - unexplained cash credit u/s 68 - HELD THAT:- No fault with the action of the ld AO, as the information was received from AIR and the return of income of the assessee did not show the complete details about the above deposit. Further, in response to the query letters of the AO, assessee did not reply. Therefore, AO has reason to believe about escapement of income. Thus ground no 1 is dismissed. Though the assessee has supported the same with the cash flow statement as well as the sum received from her professional practice and from partnership firm - when the assessee filed her return of income she included the professional income of ₹ 518831/- as well as remuneration and interest from partnership firm of Priyadarshi Hospital ₹ 219415/-. Her individual gross receipt from private practice shows Gross professional income of ₹ 885690/- which was deposited in that bank account. While explaining the source the assessee has categorically stated that, the above professional receipt was deposited in the bank account of the assessee. Therefore, addition to that extent naturally amounts to double addition. She was having opening cash balance in hand of ₹ 325492/- which was also deposited. Therefore, the addition on that account also deserves to be deleted in absence of any other finding contrary by the revenue. This left us the sum of ₹ 3 lakh received by the assessee from Priyadarshi Hospital. The assessee was a partner in that firm. Undoubtedly, the account submitted by the assessee was not authenticated by stating the PAN. We also do not find information about return of income etc of that firm in the paper book submitted by the assessee. In view of this, we direct the ld AO to delete the addition to the extent of ₹ 325492/- and ₹ 885690/-. However, with respect to the receipt of ₹ 3 lakhs from Priyadarshi Hospital requires proper verification. Accordingly, to that extent only, we set aside the issue of verification of cash receipt of only ₹ 3 lakh from Priyadarshi Hospital by the assessee back to the file of the ld AO with a direction to the assessee to submit the authentic ledger stating PAN of that partnership firm. - Appeal of the assessee is partly allowed
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