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| The Tax Publishers2020 TaxPub(DT) 1310 (Jp-Trib) INCOME TAX ACT, 1961
Section 147
The very fact of deposit of cash of Rs. 14.00 lacs and not filing of return of income by assessee, itself constituted a tangible material to form the belief that income assessable to tax had escaped assessment.
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Reassessment - Income escaping assessment - AO found that cash was deposited in bank account for Rs. 14 lacs but no return was filed by assessee -
Assessee challenged validity of reassessment proceedings wherein AO made addition of Rs. 15,50,000 on account of alleged unexplained cash under section 68. Held: AO found out facts of deposit of cash of Rs. 14.00 lacs in bank account of the assessee and no return of income was filed for year under consideration. Thus, that very fact of deposit of cash of Rs. 14.00 lacs and not filing of return of income by assessee, itself constituted a tangible material to form the belief that income assessable to tax had escaped assessment.
REFERRED : Chhugamal Rajpal v. SP Chaliha & Ors. (1971) 79 ITR 603 (SC) : 1971 TaxPub(DT) 0314 (SC); Prem Chand Shaw (Jaiswal) v. Asstt. CIT (2016) 383 ITR 597 (Cal) : 2016 TaxPub(DT) 1688 (Cal-HC); Pioneer Town Planners (P) Ltd. v. Dy. CIT (ITA No. 132/Del/2018--ITAT Delhi Bench) : 2018 TaxPub(DT) 5311 (Del-Trib); Amarlal Bajaj v. Asstt. CIT (2013) 37 Taxmann.com 7 (Mumbai Trib)
FAVOUR : Against the assessee
A.Y. :
INCOME TAX ACT, 1961
Section 69
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