ITO Vs Rajaram Ramswarup Jaju (ITAT Pune)
The Revenue filed an appeal before the Income Tax Appellate Tribunal (ITAT), Pune, against the order of the Commissioner of Income Tax (Appeals) [NFAC] for Assessment Year (AY) 2016-17. The assessee also filed a cross objection. The assessee was engaged in the business of extracting cotton seed wash oil and trading edible oil, oil cake, cotton seed, wheat, jowar, soybean, tur, chana and other commodities through its proprietorship concern, M/s Jaju Industries. It had filed its return declaring total income of ₹13,77,900. The assessment was reopened after information that cash deposits of ₹55,30,281 had been made in the assessee’s bank account during the financial year 2015-16. Following the reopening, the Assessing Officer (AO) issued a notice under Section 148 and subsequently completed the reassessment under Sections 147, 144 and 144B after the assessee failed to respond to notices seeking details of the cash deposits. The AO treated the cash deposits as unexplained money under Section 69A and assessed the total income at ₹69,08,181.
Before the Commissioner (Appeals), the assessee raised several grounds along with additional grounds. The Commissioner (Appeals) allowed the appeal on one additional ground without adjudicating the remaining grounds. The Revenue challenged that order before the Tribunal, while the assessee filed a cross objection raising seven grounds.
