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INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
SHRI. VIKRAM SINGH YADAV, AM, SHRI. PARESH M. JOSHI, JM
Shiv Kumar Jolly – Appellant
Versus
The DCIT – Respondent
| Table of Content |
|---|
| 1. overview of appeal process and grounds. (Para 1 , 2) |
| 2. submission of evidence and initial findings. (Para 3) |
| 3. outcome of cit(a) appeal. (Para 4) |
| 4. detailed articulation of deposits. (Para 5) |
| 5. nature of revenue arguments. (Para 6) |
| 6. court's directive on procedural scope. (Para 7 , 8) |
| 7. final ruling analysis. (Para 9) |
आदेश / Order
PER VIKRAM SINGH YADAV, A.M. :
This is an appeal filed by the Assessee against the order of the Ld. CIT(A)-43, New Delhi dt. 13/10/2022 pertaining to Assessment Year 2017-18 wherein the assessee has challenged the sustenance of addition of Rs. 81,10,924/- under Section 69A of the Act.
2. Briefly the facts of the case were that the return of income declaring total income of Rs. 2,02,365/- was filed by the assessee on 03/06/2017 which was selected for limited scrutiny on issue of “Large value cash deposits during the year and High value cash withdrawal during the year”. Thereafter notice under section 143(2) and 142 (1) alongwith questionnaire were issued, calling for specific information regarding the nature and source of the deposits so made in the assessee’s bank account.
2.1 In response, the assessee filed his submissions which were con
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