SUNIL JAIN Vs. INCOME TAX DEPARTMENT

JUDGEMENT

(1.) Present writ petitions have been filed challenging the reassessment notice dtd. 28/3/2021 issued under Sec. 148 of the Income Tax Act, 1961 [for short "the Act"] and the assessment order dtd. 27/3/2022 passed under Sec. 147 read with Sec. 144B of the Act for the Assessment Year 2017-18.

(2.) The relevant facts of the present cases are that the Petitioner filed his return of income for the Assessment Year 2017-2018 on 22/7/2017 showing a returned income of Rs.28,42,430.00. The case of the Petitioner was selected under limited scrutiny (computer aided scrutiny selection) by the respondent department and accordingly a notice dtd. 24/9/2018 was issued under Sec. 143(2) of the Act by the Assessing Officer against the Petitioner raising queries regarding cash deposit made by the Petitioner during the demonetisation period.

(3.) An assessment order dtd. 26/12/2019 was passed by the Assessing Officer under Sec. 143(3) of the Act for the concerned assessment year 2017-18 at an income of Rs.57,17,430.00 making an addition of Rs.28,75,000.00 to the returned income of the Petitioner under Sec. 69A of the Act on the ground that the Petitioner was not able to satisfactorily explain the source of the fund for the cash deposit of Rs.34,54,500.00 made by him in his bank account held with the Corporation Bank during the demonetisation period.