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"Reasons recorded for issuance of notice u/s. 148 of the I.T. Act in
the case of Sh. Harmeet Singh, 2/54, Geeta Colony, New Delhi for
the assessment year 2008-09.
27.03.2013 Information based on Non-filter AIR data available on the ITD
system reveals that Sh. Harmeet Singh has deposited cash of Rs.
40,49,500/- in the saving bank account on various dates during the
FY 2007-08 pertaining to AY 2008-09. Perusal of the database in
the ITD system shows that the assessee has not filed any ITR for
the AY 2008-09, thereby it can be concluded that the disclosed
income is below taxable limits and in absence of disclosed sources
of income /cash, it is reasonably concluded that income equivalent
to the cash deposits has escaped assessment and the same is
chargeable to tax for AY 2008-09. The onus to disclose the true
and full particulars of income lies on the assessee, hence it can be
concluded that assessee has failed to disclose sources of cash
deposits. In view of the explanation 2 of proviso 2 of section 147 of
the Act, since no return of income has been furnished and income
exceeds taxable limits, case of the asessee needs to be reopened
u/s. 147/148 of the Act to bring to tax the income equivalent to
cash deposit of Rs. 40,94,500/- which has escaped assessment.