HARENDRA MAHENDRABHAI PATEL,VADODARA vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

1. The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)-12, Ahmedabad dated 27/02/2025 passed u/s.250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the Assessment Year (AY) 2020-2021.

The issue raised by the assessee in this appeal is regarding confirmation of addition of Rs.3,20,000/- made by the Assessing Officer (AO) u/s.69A of the Act on account of unexplained foreign currency found at the premises of the assessee during the course of search action. The AO made Harendra Mahendrabhai Patel vs. DCIT AY : 2020-21 the impugned addition of the foreign currency equal to the value of the same in Indian currency.

The Ld. Counsel for the assessee has submitted that the small amount of foreign currency found at the premises of the assessee was left out currency out of the various foreign trips made by the assessee. He, in this respect, has relied upon the passport of the assessee. He, this respect, has submitted that the assessee and his family members had gone overseas trip in the year 2010, 2015, 2017 & 2018,. He has given chart of the foreign trips of his father Late Shri Mahendrabhai Chaturbhai Patel, his brother Hemant Kumar Mahendrakumar Patel and of the assessee Hearendra Mahendrabhai Patel,which for the sake of ready reference is reproduced as under: