9911796707
TMI Blog2024 (3) TMI 1353X X X X Extracts X X X X X X X X Extracts X X X X ..... petition for condonation of delay along with reasons for delay has been filed. After considering the petition filed by the assessee and also hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeal on or before the due date prescribed under the law and thus, in the interests of justice, we condone delay in filing of appeal and admit appeal filed by the assessee for adjudication. 3. The brief facts of the case are that, the assessee is an individual deriving income from salary from a private company. Apart from that, the assessee claims to have earned income from money lending business and agricultural activities. The assessee has filed his return of income for the assessment year 2017-18 on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d that, source for cash deposits is out of opening cash in hand, income of current year and loan received from LIC. The ld. CIT(A), after considering relevant submissions of the assessee, allowed partial relief of Rs. 3,04,115/- towards loan from LIC and also a sum of Rs. 1,69,000/- towards current year income. In other words, the ld. CIT(A) allowed relief of Rs. 4,73,115/- towards cash deposits into bank account and balance addition of Rs. 31,60,956/- has been confirmed. Aggrieved by the ld. CIT(A) order, the assessee is in appeal before us. 5. The Ld. Counsel for the assessee, Shri. S. Sridhar, Advocate (Erode), submitted that the ld. CIT(A) erred in not considering opening cash in hand available with the assessee, which is generated out ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Therefore, we are of the considered view that the assessee could not furnish sufficient evidences before the Assessing Officer and the ld. CIT(A) to explain source for cash deposits, except stating that he was having opening cash in hand at Rs. 9,00,000/- and source for cash deposits is out of opening cash in hand and realization of sundry debtors. At the same time, the Assessing Officer and the ld. CIT(A) could not adduce any reasons for not considering the explanation of the assessee with regard to opening cash in hand of Rs. 9,00,000/-. Although, the appellant could not file necessary evidences, the possibility of keeping opening cash in hand out of agricultural income declared for last two financial years cannot be ruled out. The assess ..... X X X X Extracts X X X X X X X X Extracts X X X X
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