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TMI Blog2023 (2) TMI 111X X X X Extracts X X X X X X X X Extracts X X X X ..... 18. 2. The assessee has raised various grounds of appeal on jurisdictional issue as well as on merits. However, at the time of hearing the assessee pressed only Ground No. 3 and 4, which are reproduced as under:- "3. That on facts, circumstances and legal position of the case, the Worthy CIT(A), NFAC has erred in confirming the impugned addition of Rs. 23,17,541/ by holding that cash deposit of that amount in bank accounts is from unexplained sources. 4. That on facts, circumstances and legal position of the case, the Worthy CIT(A), NFAC has erred in not allowing the ground on non-allowance of deduction of Rs. 2,10,000/- under Chapter VI A claimed by the assessee." 3. The issue raised in Ground No. 3 is against the confirmation of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ege and his personal PAN was linked to the account of college. The said information was passed on the ACIT/DCIT, Circle-1(1), Dhanbad on 04/03/2019 by the DCIT, Cir-59, Kolkata vide letter No. DCIT, Cir.59/Kol/OCM/2018-19/154 dt. 04/03/2019, for further course of action at their end. Subsequently, the ACIT, Circle-1(1), Dhanbad, vide his letter in F.No. ACIT/Cir- 1(1)/Transfer/DHN/18-19 dtd. 11/03/2019, passed on the information to the ITO, Exemption Ward, Dhanbad as the later was actually the jurisdictional A.O. Thereafter, statutory notices were duly issued and served upon the assessee. However, no reply was filed in response to the said notices. Thereafter again notice u/s 142(1) of the Act was issued on 23/08/2019 to furnish reply on 28 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y and cash which was stated to be deposited in the bank accounts of the assessee was out of advance received against the sale consideration though, the sale deed was not finally executed during the year. We also note that all these evidences were also furnished before the authorities below, however, they failed to appreciate the fact that the assessee received under the agreement to sell dated 21.05.2018 whereby the assessee has agreed to sell the flat to Shri Bhupinder Singh Liddar and Smt Kulwant Kaur Liddar and received cash as stated in clause 1(3) at page no. 2 of the agreement to sell dated 21.05.2018. 5. We have perused the agreement of sale and find that Smt. Amarjit Kaur Johal (wife of Shri Joginder Singh Johal) and Shri Joginder ..... X X X X Extracts X X X X X X X X Extracts X X X X
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