9911796707
TMI Blog2023 (5) TMI 113X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee does not have registration u/s.12A of the Act. The assessee has been filing its return of income from the assessment year 2016-17. It was the submission that during the demonetization period, the assessee temple had deposited Rs.46,50,000/- out of its cash in hand in the bank. Ld AR has placed before me the copy of the cash book for the period 1.4.2016 to 31.3.2017. Ld AR submitted that on 23.11.2016, there is an entry of cash deposit of Rs.46,50,000/-. It was the submission that the Assessing Officer had treated the cash deposit in the bank as the unexplained income of the assessee. It was the submission that the opening cash balance as on 1.4.2016 was Rs.54,62,363/-. Ld AR further drew my attention to the cash book to submit tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an issue of deemed income which is the opinion of the Assessing Officer and ld CIT(A) that is being challenged. It was the submission that as per the return of income filed by the assessee, the total Hundi collection for the year was Rs.21,93,803/- and the total Hundi collection for the period after the deposit of cash in the bank account was Rs.6,05,000/-. It was the submission that thus, the assessee at best could have only about Rs.15-16 lakhs from Hundi collection to explain the cash deposit. It was the further submission that the assessee has given different submissions before the Assessing Officer. Ld Sr DR drew my attention to page 2 of the assessment order to submit that in the first paragraph, the Assessing Officer has recorded tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terest from bank. The revenue has not been able to show that the assessee has any other source of income. The closing balance as per the cash book as on 31.3.2016 tallies with the opening balance as on 1.4.2016 at Rs.54,62,363. Admittedly, the assessee has opening cash balance which far exceeded the amount which has been deposited in the bank account. The opening cash balance as on 1.11.2016 i.e. the date immediately preceding the date of cash deposit shows that the assessee has Rs.49,79,711 in cash. Admittedly, this also is far in excess of cash deposit in the bank account. A perusal of the income and expenditure account for the period 1.4.2016 to 31.3.2017 shows a loss of Rs.14,105/- and for the assessment year 2016-17 after considering t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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