TMI Blog2018 (1) TMI 587X X X X Extracts X X X X X X X X Extracts X X X X ..... reated to be only an afterthought for which there is no cogent evidence available.”. Even before us, the AR of the assessee failed to substantiate the claim of the assessee by way of corroborative evidence and, hence, we find no infirmity in the order of the CIT(A) in confirming the addition made by the AO. Accordingly, we uphold the order of the CIT(A) and dismiss the grounds raised by the assessee - ITA No. 663/Hyd/2017 - - - Dated:- 8-12-2017 - SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER For The Assessee : Sri A.V. Raghuram For The Revenue : Smt. Suman Malik ORDER PER S. RIFAUR RAHMAN, AM: This appeal is filed by the assessee against the order of CIT(A) - 9, Hyderaba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... guments of the assessee and have gone through the original assessment order and the present assessment order under appeal. The Hon'ble ITAT has set aside the issue of unexplained money to the file of Assessing Officer to frame the assessment afresh after considering the arguments of the assessee. During the original assessment proceedings, the assessee explained that cash is available with him out of withdrawal of last two years. Assessing Officer therefore held that the serially numbered new 1000/- notes cannot be out of old withdrawals. Further, as per cash book cash on hand is not 5 lakhs but less than that. The assessee did not claim in the original assessment proceedings that the cash available is out of exchange of old currency if ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red in holding the cash found to be unexplained and confirming the addition. 4. Any other ground that may be urged at the time of hearing. 7. Considered the rival submissions and perused the material facts on record. While confirming the addition made by the AO, the CIT(A) gave a categorical finding that t he assessee did not claim in the original assessment proceedings that the cash available is out of exchange of old currency if any. This argument is brought forward now and there is no evidence furnished to substantiate this new claim even during the assessment proceeding or appellate proceedings. If the claim of the assessee is correct then the money in serial numbered notes should have come from a single source the details ..... X X X X Extracts X X X X X X X X Extracts X X X X
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