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2021 (9) TMI 410 - AT - Income TaxRevision u/s 263 - cash deposits in the bank account - case of assessee was selected for limited scrutiny for verification of “Cash Deposits” - whether the AO has duly examined the details so furnished by the assessee as part of his return of income and where required, calling for further information/documentation and examination thereof during the course of assessment proceedings? - HELD THAT:- As during the course of assessment proceedings, the AO has issued notice u/s 142(1) dated 31.05.2017 asking for copy of return of income, computation of income, books of accounts, bank statements and to explain the nature and source of cash deposits in saving bank accounts maintained by the assessee - assessee has submitted copy of his return of income, computation of income, bank statements, personal cash book, ledger, copy of capital account and balance sheets for A.Y 2014-15, A.Y 2015- 16 and A.Y 2016-17 showing the opening and closing cash in hand and has also submitted the nature and source of cash deposits during the year under consideration. Infact, the ld PCIT has also acknowledged this fact that the details of transactions in respect of cash deposits and withdrawals have been duly submitted by the assessee during the assessment proceedings. The submissions so made have been examined by the AO as evident from clear affirmation thereof by the AO in the assessment order. The matter has been duly examined by the AO with focus on cash deposits and withdrawals transactions made by the assessee during the year for which the matter was selected for limited scrutiny - where the AO has examined the personal cash book maintained by the assessee showing cash in hand, deposits and withdrawals made during the year and the opening and closing balances of cash in hand are duly reflected in the respective balance sheets of previous and subsequent years, we find that the AO has taken all reasonable steps as are expected to be taken to verify the subject transactions in terms of nature and source of such deposits. Balance sheets not just reflect the cash in hand rather reflect the state of affairs in terms of assets and liabilities as on the close of the financial year including the net results of the activities undertaken by the assessee during the year - where the net results of the activities so undertaken has been accepted by the ld PCIT as reflected in the return of income in terms of net income and further, where no adverse finding has been recorded regarding the status of assets and liabilities, it would be incorrect to hold that the balance sheet is not authentic merely for the fact that the assessee has failed to report certain details in the return of income. Necessary enquiries and examination as reasonably expected have been carried out by the Assessing officer and he has taken a prudent, judicious and reasonable view after considering the entire material available on record and the order so passed u/s 143(3) cannot be held as erroneous in so far as prejudicial to the interest of Revenue - Decided in favour of assessee.
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