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Ammati Venkatachalapathisetty Satish ... vs Income Tax Officer, Ward-1, ... on 24 February, 2026 cites

Common Cause (A Regd. Society) vs Union Of India on 9 March, 2018

ITA No.2039 - 2041/Bang/2025 Page 17 of 20 According to the learned AR, this entire exercise was based only on estimation and presumption without any supporting evidence. 33.1 It was further contended that no incriminating material was found during the survey to show unaccounted sales or purchases. The addition was made merely relying on the statement recorded, without any corroborative evidence. The ld. AR pointed out that all sales were duly recorded in the books and income was declared under section 44AD of the Act. The books of account were not rejected by the AO and even the purchases were not doubted. Therefore, the addition made on ad-hoc assumptions was not justified and liable to be deleted. 33.2 The learned AR also relied on judicial precedents, including the decision of the Hon'ble Supreme Court in Common Cause vs Union of India (77 taxmann.com 245) and the decision of the ITAT Bangalore Bench in the case of EMKAY Hindustan Infrastructure in ITA No. 979/Bang/2022, to submit that addition cannot be sustained merely on the basis of statement without supporting material. He therefore prayed that the entire addition be deleted.
Supreme Court of India Cites 130 - Cited by 396 - D Misra - Full Document

Commissioner Of Income-Tax, Uttar ... vs Devi Prasad Vishwanath Prasad on 1 August, 1968

ITA No.2039 - 2041/Bang/2025 Page 4 of 20 Officer found that there was no clear and satisfactory explanation establishing a nexus between earlier withdrawals and the subsequent cash deposits. The loan amount received by cheque could not explain the cash deposits, particularly when the cash was separately credited in the bank account. The assessee also failed to reconcile the cash flow and refused to properly certify the accounts under Rule 14 despite specific directions. The inconsistencies in the opening and closing balances for preceding and succeeding years further weakened the explanation. Placing reliance on the principles laid down by the Hon'ble Supreme Court in the cases of CIT v. Devi Prasad Vishwanath Prasad reported in 72 ITR 194 and CIT v. P. Mohankala reported in 291 ITR 278, the Assessing Officer held that the burden was on the assessee to satisfactorily explain the nature and source of the sums credited. Since the explanation was not found satisfactory, the cash deposits of Rs. 19,00,000 were treated as unexplained income and added to the total income of the assessee.
Supreme Court of India Cites 5 - Cited by 187 - Full Document

Additional Commissioner Of ... vs Mohanlal P. Jain And Ors. on 26 August, 1975

ITA No.2039 - 2041/Bang/2025 Page 4 of 20 Officer found that there was no clear and satisfactory explanation establishing a nexus between earlier withdrawals and the subsequent cash deposits. The loan amount received by cheque could not explain the cash deposits, particularly when the cash was separately credited in the bank account. The assessee also failed to reconcile the cash flow and refused to properly certify the accounts under Rule 14 despite specific directions. The inconsistencies in the opening and closing balances for preceding and succeeding years further weakened the explanation. Placing reliance on the principles laid down by the Hon'ble Supreme Court in the cases of CIT v. Devi Prasad Vishwanath Prasad reported in 72 ITR 194 and CIT v. P. Mohankala reported in 291 ITR 278, the Assessing Officer held that the burden was on the assessee to satisfactorily explain the nature and source of the sums credited. Since the explanation was not found satisfactory, the cash deposits of Rs. 19,00,000 were treated as unexplained income and added to the total income of the assessee.
Gujarat High Court Cites 18 - Cited by 148 - Full Document
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