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2022 (3) TMI 1025 - ITAT INDOREReopening of assessment u/s 147 - Addition treating the deposits in bank account as unexplained income - HELD THAT:- When we look into the cash flow statement, we observe that the assessee has made a single cash withdrawal on 21.12.2011, which shows that the assessee is making high cash withdrawals too, though there are small withdrawals of course as stated by CIT(A) - to say that the assessee is making only small withdrawals, is baseless. We also note from the cash flow statement that the assessee has shown a closing cash balance which supports the fact that the assessee is keeping high cash balance as well. Another observation made by Ld. CIT(A) and emphasized by Ld. DR too that the assessee is declaring only ₹ 10,000/- per month and the household expenses cannot be as low as ₹ 300/- per day, is also a self-drawn inference for the sake of argument and does not have much substance unless the lower authorities would have found substantial household expenditure of the assessee on the basis of some material. With these facts on record, we observe that the assessee has submitted cash flow statement wherein the sources of deposits in bank account are well explained and this statement is not conclusively and adequately rebutted by the lower authorities. Hence we are inclined to hold that the assessee has explained the source of deposits and the same deserves to be accepted. Therefore, we allow this Ground of assessee.
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