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2022 (12) TMI 580 - ITAT AMRITSARReopening of assessment u/s 147- unexplained cash deposits - Assessee filed the return but had not disclosed the deposit of cash in the return of income - assessee took the plea that the said amount was accumulated for the sale of land, but the assessee was unable to produce any instrument related to proof of sale of land.HELD THAT:- In the factual ground the grievance of the revenue that the acceptance of the instrument related to transfer of the property like agreement and power of attorney was in question. In the hearing before bench, the assessee also placed the registered power of attorney and the copy of the agreement as proof of the transaction. The revenue authority had not verified the purchaser of the property M/s R.K. Associates, Grain Market, Tanda, Distt., Hoshiarpur. In our opinion, the primary evidence, and party who paid the cash to the assessee for purchasing the land before the Bench, was unable to submit any registered deed related to transfer of property. As per the ld. Sr. DR, the total transfer of the land is incomplete without a registered deed of the property. But the ld. Counsel argued that the source of the cash was proved on basis of this transaction. In any case, we are set aside the issue to ld. AO for verification to the purchaser of the property M/s R.K. Associates. The issue should be disposed off accordingly with the above direction. Appeal of the assessee is allowed for statistical purposes.
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