RAJ KUMAR GUPTA,TINSUKIA vs. CENTRAL CIRCLE-1, GUWAHATI

The sole issue raised by the assessee is against the confirmation of addition by CIT (A) of ₹6,46,430/- as made by the ld. AO u/s 69A of the Income-tax Act, 1961 (the Act) and ₹1,96,000/- which was realized from sale of vehicle. 4. The facts in brief are that the cash amount of ₹10,50,000/- was from seized from the assessee by State Surveillance Team on 04.03.2021, after the assessee was intercepted during the course of Assam General Election 2021. Warrant of authorization u/s 132A of the Act was issued and cash was requisitioned on 11.03.2021, from the concerned authority. Thereafter, the assessee filed the return of income showing total income at ₹4,91,250/-. The statutory notices along with questionnaire were issued which were replied by the assessee by submitting the source of cash deposits. The ld. AO finally partly accepted the submission of the assessee. However, the contention of the assessee is that ₹6,45,400/- was received from the four persons on account of LIC premium and ₹1,96,000/- from sale of cars. The contentions of the assessee were not accepted and accordingly addition was made to the income of the assessee in the assessment framed u/s 143(3) of the Act vide order dated 22.09.2022. 5. In the appellate proceedings, the ld. CIT (A) dismissed the appeal of the assessee by upholding the order of the ld. AO on both the issues. 6. After hearing the rival contentions and perusing the materials available on record, we find that though the assessee has submitted that the money was received from 4 individual as LIC premium and also from sale of cars. We note that ₹6,46,430/- was stated to be received from 4 LIC holders, whereas ₹1,96,000/- was stated to be received from sale of vehicle. However, we note that the summons Raj Kumar Gupta; A.Y. 2021-22