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2024 (2) TMI 1517

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..... g question of law arising out of the order dated 24.05.2023 passed by the Income Tax Appellate Tribunal, Surat Bench (SMC), Surat (for short "the Tribunal") in ITA No.328/SRT/2022 for AY 2015-16. "[A] Whether the Learned Tribunal was right in law to sustain the addition of unexplained cash credit amounting to Rs. 22,00,000/- by invoking provision of income tax act, 1961 as unexplained income?" 3. The appellant-assessee is a Hindu Undivided Family (for short "HUF") filed return of income for A.Y.2015-16 on 29.03.2016 declaring total income of Rs. 3,21,069/-. 4. The Assessing Officer by the Assessment order under Section 143(3) of the Act after considering the cash deposit of Rs. 24,80,000/- in the saving bank account with the Allahabad B .....

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..... ot furnished the source of cash and cheque deposits. Before me, the Id AR for the assessee except contending that the assessee has sufficient cash balance for making deposit in bank, has not explained the real source of cash and cheque deposits. I find that the assessing officer in his summary has clearly demonstrated the cheque deposits and immediate withdrawal or on deposits of money in cash immediately transferred by way of cheque, the assessee has failed to give any satisfactory reply against the finding of the assessing officer. I am in full agreement with the observation of the assessing officer that the assessee has only shown source of income from agriculture activities. However, keeping in view the general practice in society that .....

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..... e addition of Rs. 22,00,000/- out of Rs. 24,80,000/- by the Assessing Officer confirmed by the CIT(Appeal). 10. It appears from the explanation placed on record along with the memo of appeal by way of paper book, in the submissions made before the CIT(Appeal) the assessee tried to explain the cash deposit in the bank account, however such explanation is not accepted either by the CIT(Appeal) as well as the Tribunal. 11. In view of the concurrent findings of fact, arrived at by the authorities, we are of the opinion that no question of law, much less any substantial question of law arises from the impugned order of the Tribunal. The appeal therefore being devoid of any merit is accordingly dismissed.
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