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The entire addition made by AO/Ld. CIT(A) of the total amount deposited in the two undisclosed bank accounts to the tune of Rs. 21,92,100/- is erroneous.

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Sec. 68 of Income Tax Act, 1961—Cash Credit— The combined peak credit in respect of both the banks need to be taken to find out the undisclosed investments made by the assessee for the undisclosed transaction in both banks which needs to be added in the hands of the assessee and since the AO failed to bring on record any material to show that the assessee was doing any other business other than the grocery business, the inference that can be drawn is that the assessee was doing undisclosed transaction in respect of grocery from grey market without any bills etc, therefore, assessee was engaged in the business of grocery through these undisclosed bank accounts, thus,the entire addition made by AO/ CIT(A) of the total amount deposited in the two undisclosed bank accounts is erroneous. - SMT. LAXMIYADAV V/s ITO - [2020] 27 ITCD Online 019 (ITAT-KOLKATA)