TMI Blog2021 (1) TMI 1003X X X X Extracts X X X X X X X X Extracts X X X X ..... missible to examine the source of Mr. Nagaraj as that would amount to examining source of source. With these observations, we set aside the order of the CIT(A) and allow the appeal of the assessee for statistical purposes. - ITA No. 1727/Bang/2019 - - - Dated:- 25-1-2021 - SHRI N. V VASUDEVAN, VICE-PRESIDENT Assessee by : Shri. V. Narendra Sharma, Advocate Revenue by : Shri. Ganesh R. Ghale, Jr. Standing Counsel ORDER PER SHRI N.V VASUDEVAN, VICE-PRESIDENT : This is an appeal of the assessee against the order dated 05.07.2019 of CIT(A)-7, Bengaluru, relating to Assessment Year 2016-17. 2. The only issue that arises for consideration in this appeal is as to whether the Revenue authorities were justified in a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the bank account of M/s. Annapurneshwari Rice Industries and he found that the assessee had deposited cash of ₹ 20 lakhs into the bank account of M/s. Annapurneshwari Rice Industries. In these circumstances, the AO was of the view that the money which was obtained as loan from M/s. Annapurneshwari Rice Industries was nothing but assessee s own money which was routed as a loan through M/s. Annapurneshwari Rice Industries. 4. When the assessee was confronted with the above facts, the assessee vide letter dated 18.12.2018 submitted as follows: 1 was in need of funds to the tune of ₹ 20,00,000 to discharge business obligations. So 1 approached Sri Nagaraj, partner of M/s Annapoomeshwari Rice Industries on the night of 04. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rusal. 5. The AO, however, took the view that M/s. Annapurneshwari Rice Industries did not have sufficient capacity to lend a sum of ₹ 20 lakhs and in this regard, has tabulated the income declared by M/s. Annapurneshwari Rice Industries from Assessment Years 2010-11 to 2016-17. The income declared was a sum of ₹ 1,99,000/- only. The AO therefore held that the sum of ₹ 20 lakhs was unexplained cash credit and added the same to the income of the assessee under section 68 of the Act. On appeal by the assessee, the CIT(A) confirmed the order of the AO. 6. Aggrieved by the order of CIT(A), the assessee has preferred the present appeal. 7. We have heard the submissions of the learned AR. He submitted that the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X
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