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2022 (12) TMI 842

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..... e assessee, is directed against the order of the learned Commissioner of Income-tax (Appeals)-30, New Delhi, dated 27.05.2022, pertaining to the assessment year 2017-18. The assessee has raised following grounds of appeal: "1. Because the action for initiation, continuation and conclusion of assessment proceedings u/s 143(3) at an amount of Rs 17,78,840/- is being challenged on facts & law. 2. .....

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..... dification in the grounds of appeal before the disposal of the same in the interest of substantial justice to the assessee." 2. Facts giving rise to the present appeal are that in this case the assessee had filed his return of income through electronic mode on 05.08.2017 declaring total income of Rs. 10,63,840/-. Thereafter the case of the assessee was selected for limited scrutiny through CASS f .....

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..... learned counsel for the assessee vehemently argued that authorities below were not justified and have proceeded purely on conjectures and surmises and the addition has been made purely on ad hoc basis without being supported by any credible evidence. On the contrary, the assessee had given supporting evidence relating to the cash deposited by the assessee. 5. The learned DR opposed the submission .....

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..... 2016 to 04.11.2016 was though made to meet household expenses and other investment needs but was not spent during the period and, same was deposited in his bank account after the demonetization of specified bank-notes. The claim of the appellant appears to be un-reliable as the withdrawal of amounts appears to be for the purpose of personal and household expenses which were withdrawn almost every .....

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..... utilized for domestic needs and rest of the amount was deposited in the bank account. I find that the authorities below have not given any cogent reason for not accepting the explanation offered by the assessee. In the absence of any evidence by the assessing authority that the amount which was available in the form of withdrawals from bank was utilized by the assessee for any other purpose, the a .....

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