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2022 (12) TMI 1345 - AT - Income TaxValidity of reopening of assessment u/s 147 - Unexplained source of the cash deposits in the bank accounts - HELD THAT:- It is evident, in the year under consideration, the assessee has deposited cash amounting to Rs.58,86,000 in two bank accounts standing in his name. It is a fact on record that the assessee did not file any return of income u/s 139(1). The fact relating to cash deposit made by the assessee came to the notice of the Assessing Officer from the individual transaction statement available with the department. Thus, in absence of any return of income filed by the assessee, the Assessing Officer had no other information to suggest that the cash deposits reflected in the individual transaction statement has been offered to tax by the assessee. Therefore, while reopening the assessment under Section 147 of the Act, the Assessing Officer had tangible material in his possession to form belief that income has escaped assessment. Therefore, he has validly initiated proceedings under Section 147 of the Act. Validity of approval granted under Section 151 - We do not find any deficiency in such approval. Therefore, no merit in ground no.2. Accordingly, the ground is dismissed.
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