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2024 Supreme(Online)(ITAT) 9615

INCOME TAX APPELLATE TRIBUNAL (INDORE BENCH)
Shri Vijay Pal Rao, J, Shri B.M. Biyani, A.M.
LATE MANOHARASINGH THROUGH LEGAL HEIR SHRI SURAJ MANDLOI INDORE – Appellant
Versus
ITO 1(1) INDORE – Respondent


Table of Content
1. background of appeal regarding unexplained cash deposits. (Para 1 , 2)
2. challenges upon initial assessment findings. (Para 4 , 10)
3. assessment of cash sources and evidence by the court. (Para 6 , 11 , 12)
4. discussion on the retroactive application of amended tax rates. (Para 15 , 16)
5. final ruling on the appeal based on evidentiary grounds. (Para 17)

आदेश/ORDER

Per B.M. Biyani, A.M.:

Feeling aggrieved by appeal-order dated 06.12.2019 passed by learned Commissioner of Income-Tax (Appeals)-NFAC, Delhi [“CIT(A)”] which in turn arises out of assessment-order dated 06.12.2019 passed by learned ITO- 1(1), Indore [“AO”] u/ s 143(3) of Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2017-18, the assessee has filed this appeal.

2. The background facts leading to present appeal are such that the assessee filed return of AY 2017-18 on 30.03.2018 declaring aggregate income of Rs. 7,39,140/ - consisting of taxable income of Rs. 3,02,220/ - from other sources and agricultural income of Rs. 4,36,920/ -, which was subjected to “limited scrutiny” assessment through CASS to examine “cash deposits during demonetization period”. Accordingly, the AO issued notices u/ s 1

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