Manubhai Dahyabhai Bhoi vs. Income Tax Officer

Parties Involved

Facts Summary

The assessee, a resident of Anand and a teacher, undertook contract work for the assessment year 2011-12. The assessment proceedings were initiated under section 147 of the Income Tax Act as the assessee had not filed his return within the prescribed time. The assessee filed his return on 11.04.2018 declaring total income of ₹4,61,800/-. During scrutiny, the Assessing Officer observed substantial cash deposits in the assessee's bank accounts amounting to ₹14,20,000/- in SBI and ₹15,00,000/- in HDFC Bank. The assessee explained these deposits as contract income, sale of agricultural land, withdrawal from his wife's account, and gifts received on his son's marriage. The Assessing Officer accepted the source of ₹9,00,000/- and ₹1,00,000/- but found the remaining deposits unexplained under section 69A of the Act, adding ₹18,51,500/- to the assessee's total income.…

Legal Issues

• 1. Whether the Ld. Assessing Officer erred in reopening the case under Section 147 and 148 of the Act.
• 2. Whether the Ld. CIT(A) erred in passing an Ex-parte order and dismissing the appeal without appreciating the facts.
• 3. Whether the Ld. CIT(A) erred in confirming the addition of Rs. 18,51,500/- made by AO wrongly invoking the provisions of Section 69A of the Act.
• 4. Whether the Ld. CIT(A) erred in confirming the addition of Rs. 18,51,500/- made on account of cash deposits reflected in the bank.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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