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2023 (3) TMI 98 - AT - Income TaxReopening of assessment u/s 147 - Addition u/s 68 - HELD THAT:- The authorities below failed to give set off of such withdrawals. Considering the fact that there was cash withdrawals during the year under consideration, the addition is restricted to a sum of Rs. 2,50,000/-, as the probability of utilization of withdrawals cannot be ruled out The grounds raised against legality of reopening on the basis that there was no failure on the part of assessee, it is recorded by the AO that no return was filed by the assessee and there was huge transaction in shares. The grounds raised by the assessee are dismissed. Thus, addition made in respect of cash deposits is sustained to the extent of Rs. 2,50,000/- and in respect of share transactions, the addition made by the Revenue is hereby confirmed. The grounds of appeal are partly allowed.
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