BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

37 results for “house property”+ Section 10(3)clear

Sorted by relevance

Mumbai4,724Delhi4,033Bangalore1,491Chennai1,109Jaipur823Karnataka804Ahmedabad779Kolkata747Hyderabad705Pune626Chandigarh433Surat320Indore309Cochin274Visakhapatnam273Telangana209Amritsar163Rajkot156Raipur134Lucknow112Cuttack106Nagpur104SC80Agra75Calcutta66Patna59Jodhpur57Guwahati45Allahabad37Dehradun35Varanasi24Rajasthan24Kerala20Ranchi15Jabalpur13Panaji11Orissa9Punjab & Haryana5A.K. SIKRI ROHINTON FALI NARIMAN4Andhra Pradesh2Gauhati2Himachal Pradesh2J&K1D.K. JAIN JAGDISH SINGH KHEHAR1H.L. DATTU S.A. BOBDE1ARIJIT PASAYAT C.K. THAKKER1ANIL R. DAVE SHIVA KIRTI SINGH1T.S. THAKUR ROHINTON FALI NARIMAN1

Key Topics

Section 25052Addition to Income33Section 153A26Section 15424Section 143(3)23Section 6921Section 5416Section 143(2)15House Property15

RAJESH KUMAR JAISWAL,,ALLAHABAD vs. DEPUTY/ACIT(CENTRAL), ALLAHABAD

In the result, the appeal of the assessee is partly allowed

ITA 16/ALLD/2023[2018-19]Status: DisposedITAT Allahabad02 May 2025AY 2018-19

Bench: the query raised by the assessing authority vide questionnaire issued under section 142 (1) dated 23.01.2021, in assessment proceedings for the AY 2018-19.

For Appellant: Sh. Nikhil Agarwal & Ms. VidishaFor Respondent: Sh. A.K. Singh, Sr. DR
Section 115Section 115BSection 142Section 24Section 250Section 68Section 69

house property as received by the appellant on account of rent from Hewett Road Property and property situated at Katra, Allahabad, treating the same as business income which is against the evidence on record filed by the appellant. 8. Because in case of treating the rental income as business income of the applicant the authority's below were bound

Showing 1–20 of 37 · Page 1 of 2

Search & Seizure14
Section 13213
Natural Justice8

ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

ITA 89/ALLD/2020[2016-17]Status: DisposedITAT Allahabad31 Jan 2025AY 2016-17

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Ashish Bansal, AdvocateFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 11Section 12Section 143(3)Section 2(15)Section 260A

property and the AO had concluded that these discounts and reservations on allotment gave undue preferential treatment to the employees who were specified persons in section 13(3) of the Income Tax Act, thereby violating section 13(3) of the Income Tax Act. The learned CIT(A) held that since the order of the U.P. Government dated 17.12.1999 applied

ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

ITA 88/ALLD/2020[2015-16]Status: DisposedITAT Allahabad31 Jan 2025AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Ashish Bansal, AdvocateFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 11Section 12Section 143(3)Section 2(15)Section 260A

property and the AO had concluded that these discounts and reservations on allotment gave undue preferential treatment to the employees who were specified persons in section 13(3) of the Income Tax Act, thereby violating section 13(3) of the Income Tax Act. The learned CIT(A) held that since the order of the U.P. Government dated 17.12.1999 applied

ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

ITA 87/ALLD/2020[2014-15]Status: DisposedITAT Allahabad31 Jan 2025AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Ashish Bansal, AdvocateFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 11Section 12Section 143(3)Section 2(15)Section 260A

property and the AO had concluded that these discounts and reservations on allotment gave undue preferential treatment to the employees who were specified persons in section 13(3) of the Income Tax Act, thereby violating section 13(3) of the Income Tax Act. The learned CIT(A) held that since the order of the U.P. Government dated 17.12.1999 applied

BRAJESH AGRAWAL,PRAYAGRAJ vs. ASST. DIRECTOR OF INCOME TAX, BENGALURU

In the result, the appeal of the assessee is allowed

ITA 3/ALLD/2023[2021-22]Status: DisposedITAT Allahabad24 Mar 2023AY 2021-22

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2021-22 Brajesh Agrawal, V. Asstt. Director Of Income Tax, Cpc, Bengaluru 3/15, Patrika Marg, Civil Lines, Allahabad, U.P. Pan-Acbpa3797R (Appellant) (Respondent) Assessee By: Sh. Saurabh Agrawal, C.A. Respondent By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.03.2023 Date Of Pronouncement: 24.03.2023 O R D E R

For Appellant: Sh. Saurabh Agrawal, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 139(1)Section 143(1)Section 143(1)(a)Section 24

section 10 of the Income Tax Act. In the return of income, the assessee has declared business loss of Rs. 7,63,940/- and income from house property of Rs. 7,88,200/-. The assessee has also declared income from other sources at Rs. 3

M/S. SUBHASH STONE INDUSTRIES (P) LTD.,NAINITAL vs. DCIT, CENTRAL CIRCLE, ALLAHABAD

In the result, appeal filed by the assessee in ITA no

ITA 141/ALLD/2017[2008-09]Status: DisposedITAT Allahabad19 May 2022AY 2008-09

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: NoneFor Respondent: Shri Ramendra Kumar
Section 132Section 143(3)Section 153A

Housing Development Company Vs. DCIT Central Circle-I, Bangalore in ITA No. 38/2014 dated 25.07.2014 wherein the Hon’ble Court held that the assessing authority shall determine the total income of the assessee taking into consideration the materials which was the subject matter of earlier return and the undisclosed income unearthed during search and also any other income which comes

SANJAY MAJUMDAR,ALLAHABAD vs. PR. CIT, ALLAHABAD

ITA 68/ALLD/2018[2012-13]Status: DisposedITAT Allahabad28 Jan 2021AY 2012-13

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2012-13 Mr. Sanjay Majumdar, V. The Principal Commissioner Type Ii – 112, Devprayagam Of Income Tax, Sangam Vatika – Jhalwa, Aayakar Bhawan, Allahabad 211012 38, M.G. Marg, Civil Lines, Allahabad 211001 Pan: Adopm 2688P (Appellant) (Respondent)

For Appellant: Shri Basudev Banerjee, CAFor Respondent: Shri Debashish Chanda, CIT-DR
Section 147Section 154Section 263

10 and 41 respectively at Minto Road, Allahabad including 3 out houses bearing Nos. 42/9/1, 39/9/3 & 38/9/4 which are situated at plot no. 6 Rajapur, Bandhwa, Allahabad. The total area of land was of 2593.58 Sq. Meter. Shri Narain Das Majumdar was the lessee of this property vide lease deed dated 18.10.1937 executed by the then Collector of Allahabad. Shri

M/S GANGA NURSING HOME,,ALLAHABAD vs. DCIT,, ALLAHABAD

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 186/ALLD/2013[2008-09]Status: DisposedITAT Allahabad10 Sept 2021AY 2008-09

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143Section 143(3)Section 2(14)Section 2(14)(iii)Section 50C

10%. The description of land sold as is mentioned in this second sale deed is property number Aarazi No. 327/1, situated at Ward Aarel, Neweda, Samogar, Tehsil Karchanna, District Allahabad , the total area of the said property as is mentioned in the sale deed comes to 0.857 hectares and the assessee has sold its 1/3 share in the aforesaid property

SHOBHA RASTOGI,ALLAHABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, ALLAHABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 47/ALLD/2020[2008-09]Status: DisposedITAT Allahabad13 Aug 2021AY 2008-09

Bench: Shri.Vijay Pal Raoassessment Year: 2008-09 Smt. Shobha Rastogi, V. Deputy Commissioner Of Income 30-A, M.G. Marg, Civil Lines, Tax, Circle-1, Allahabad, U.P. Allahabad, U.P. Pan-Afqpr4774R (Appellant) (Respondent) Appellant By: Mr. Praveen Godbole, C.A. Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 12.08.2021 Date Of Pronouncement: 13.08.2021

For Appellant: Mr. Praveen Godbole, C.AFor Respondent: Mr. A.K. Singh, Sr. DR
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 50C

house of property in question. However, the assessee claimed that the sale was not concluded in the assessment year 2007-08 but it was concluded in the assessment year 2008-09. The Assessing Officer did not proceed to assess the income arisen from the sale of the property in question and consequentially the assessment for the assessment year

MEJA URJA NIGAM (P) LTD.,ALLAHABAD vs. INCOME TAX OFFICE WARD-2 (2), ALLAHABAD

In the result, both the appeals of the assessee for ay: 2015-16 and 2016-17

ITA 54/ALLD/2020[2015-16]Status: DisposedITAT Allahabad03 Mar 2021AY 2015-16

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

For Appellant: Ms.Namita S. Pandey, CIT DRFor Respondent: Shri Parv Agrawal, CA
Section 143(3)

3) of the 1961 Act and admit both these appeals for ay: Assessment Years: 2015-16 & 2016-17 2015-16 and 2016-17 respectively, to be now adjudicated on merits. We order accordingly. ITA No. 54/Alld/2020- Assessment Year- 2015-16 5. The brief facts of the case are that the assessee is a Public Sector Undertaking which

SUCHITRA TANDON,PRAYAGRAJ vs. ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE - 2 ALLAHABAD, ALLAHABAD

In the result, the appeal of the assessee stands dismissed

ITA 10/ALLD/2025[2015-16]Status: DisposedITAT Allahabad14 May 2025AY 2015-16

Bench: Shri Subhash Malguria & Shri Sanjay Awasthi

Section 54

10 SOT 655 (Cochin) (ii) Smt. Janki Kishan Hingorani vs. Pr. CIT [2024] 158 taxmann.com 3 (Rajkot-Trib.) (iii) CIT vs. Zaibunnissa Begum [1985] 151 ITR 320 (AP) (iv) Smt. Asha George vs. Income Tax Officer [2013] 351 ITR 123 (Kerala) I.T.A. No.10/Alld/2025 Assessment Year:2015-16 6 6. We have heard the rival parties and have gone through

M/S DEORA ELECTRIC WORKS,,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result, the appeal of the assessee is partly allowed

ITA 637/ALLD/2014[2010-11]Status: DisposedITAT Allahabad20 Mar 2025AY 2010-11

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2010-11 M/S Deora Electric Works V. The Jcit 58-A, Sardar Patel Marg Range – I Allahabad Allahabad Pan:Aadfd7479B (Appellant) (Respondent) Appellant By: Shri Praveen Godbole, C.A. Respondent By: Shri A. K. Singh, Sr. D.R. Date Of Hearing: 17 01 2025 Date Of Pronouncement: 20 03 2025 O R D E R

For Appellant: Shri Praveen Godbole, C.AFor Respondent: Shri A. K. Singh, Sr. D.R
Section 143(3)Section 145(3)Section 250

properties of the firm, they were used by the firm for business purposes and ITA No.637/ALLD/2014 Page 8 of 21 hence the expenditure had been claimed. Regarding payment of electricity and telephone on account of partners, Shri Pawan Kumar Deora and Shri Ashok Kumar Deora, it was submitted that a part of their house was used for office premises

MADHURENDRA NATH,ALLAHABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

In the result, both the appeals in ITA No

ITA 16/ALLD/2018[2013-14]Status: DisposedITAT Allahabad16 Feb 2023AY 2013-14

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2013-14 Vs. The Asstt. Commissioner Of Smt. Neeta Nath, L/H Of Lt. Dr. Jitendra Nath Income Tax, Central Circle, Civil Lines, Allahabad B/401, Mayan Enclave, 49/13, Clive Road, Allahabad Pan-Abepn1795Q (Appellant) (Respondent) Assessment Year: 2013-14 Madhurendra Nath, Vs. The Asstt. Commissioner Of B-502, Vinayak Le Grande, Income Tax, Central Circle, 16/12, Lal Bahadur Shastri Civil Lines, Allahabad Road, Allahabad-211001 Pan-Aaipn8161D (Appellant) (Respondent) Appellant By: Sh. Siddharth Pathak, Adv Respondent By: Sh. Rabin Chaudhari, Cit Dr Date Of Hearing: 18.01.2023 Date Of Pronouncement: 16.02.2023 O R D E R Shri Vijay Pal Rao, J.M.: These Two Appeals By The Two Related Assessees Are Directed Against Two Separate Orders Of The Cit(A), Both Dated 28.04.2016 For The Assessment Year 2013-14. 2. These Appeals Are Arising From The Assessment Orders Passed Under Section 153C In Pursuant To The Search & Seizure Action Under Section 132(1) Of The Income Tax Act, Dated 05.12.2013 In The Case Of Shri. Hemant Kumar Sindhi. Therefore, The Facts & Circumstances As Well As The Grounds Of Appeal

For Appellant: Sh. Siddharth Pathak, AdvFor Respondent: Sh. Rabin Chaudhari, CIT DR
Section 132(1)Section 143(2)Section 153C

property was happened between M/s H.K. Infraventures Pvt. Ltd. through its Director Shri Hemant Kumar Sindhi and with Dinesh Kumar Pahuja President of Sindhu Sahkari Avas Samiti and the contrary view taken by the Id. CIT(Appeals) to confirm the addition in the hands of appellant is wholly illegal and erroneous. 8. BECAUSE there was no business dealings with Dinesh

SMT. NEETA NATH L/H OF LATE DR. JITENDRA NATH,ALLAHABAD vs. ACIT, CENTRAL CIRCLE, ALLAHABAD

In the result, both the appeals in ITA No

ITA 15/ALLD/2018[2013-14]Status: DisposedITAT Allahabad16 Feb 2023AY 2013-14

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2013-14 Vs. The Asstt. Commissioner Of Smt. Neeta Nath, L/H Of Lt. Dr. Jitendra Nath Income Tax, Central Circle, Civil Lines, Allahabad B/401, Mayan Enclave, 49/13, Clive Road, Allahabad Pan-Abepn1795Q (Appellant) (Respondent) Assessment Year: 2013-14 Madhurendra Nath, Vs. The Asstt. Commissioner Of B-502, Vinayak Le Grande, Income Tax, Central Circle, 16/12, Lal Bahadur Shastri Civil Lines, Allahabad Road, Allahabad-211001 Pan-Aaipn8161D (Appellant) (Respondent) Appellant By: Sh. Siddharth Pathak, Adv Respondent By: Sh. Rabin Chaudhari, Cit Dr Date Of Hearing: 18.01.2023 Date Of Pronouncement: 16.02.2023 O R D E R Shri Vijay Pal Rao, J.M.: These Two Appeals By The Two Related Assessees Are Directed Against Two Separate Orders Of The Cit(A), Both Dated 28.04.2016 For The Assessment Year 2013-14. 2. These Appeals Are Arising From The Assessment Orders Passed Under Section 153C In Pursuant To The Search & Seizure Action Under Section 132(1) Of The Income Tax Act, Dated 05.12.2013 In The Case Of Shri. Hemant Kumar Sindhi. Therefore, The Facts & Circumstances As Well As The Grounds Of Appeal

For Appellant: Sh. Siddharth Pathak, AdvFor Respondent: Sh. Rabin Chaudhari, CIT DR
Section 132(1)Section 143(2)Section 153C

property was happened between M/s H.K. Infraventures Pvt. Ltd. through its Director Shri Hemant Kumar Sindhi and with Dinesh Kumar Pahuja President of Sindhu Sahkari Avas Samiti and the contrary view taken by the Id. CIT(Appeals) to confirm the addition in the hands of appellant is wholly illegal and erroneous. 8. BECAUSE there was no business dealings with Dinesh

M/S. GOVIND STONE PRIVATE LIMITED ,HAMIRPUR vs. INCOME TAX OFFICER -5(4), BANDA

ITA 258/ALLD/2018[2013-14]Status: DisposedITAT Allahabad19 Dec 2022AY 2013-14

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri. R. S. Agrawal, Adv. &VinayGoel, C.AFor Respondent: Shri A.K. Singh Sr.D.R
Section 143Section 143(2)Section 143(3)Section 56Section 68

house, 4 Faile Place, Notice Served Private Limited 2nd Floor, Kolkata-700001 2 AprajitaVanijya 7A, Bentinck Street, Insufficient address, Private Limited Kolkata-700001 hence returned to sender Zigzag Vanijya 146/2, Old China Bazar, No mention floor 3 Private Limited Kolkata-700001 R/No. hence R. to sender 4 ShradhaVintrade 9/12, Lal Bazar, 2nd Floor, Insufficient address, Private Limited Kolkata-700001 hence

I.T.O., WARD-1(4), ALLAHABAD vs. RAGHAV WADHAWAN, NEW DELHI

In the result, the appeal is dismissed

ITA 184/ALLD/2017[2012-13]Status: DisposedITAT Allahabad21 Nov 2019AY 2012-13

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2012-13 Income Tax Officer V. Shri Raghav Wadhawan Ward 1(4) C-51, 3Rd Floor Allahabad Friends Colony New Delhi Tan/Pan:Aaopw9056A (Appellant) (Respondent) Appellant By: Shri S. K. Madhuk, Cit (Dr) Respondent By: Shri Ashok Kumar, C.A. Date Of Hearing: 20 11 2019 Date Of Pronouncement: 21 11 2019 O R D E R

For Appellant: Shri S. K. Madhuk, CIT (DR)For Respondent: Shri Ashok Kumar, C.A
Section 10(22)Section 54

10(22). The literal construction would lead to manifestly unreasonable and absurd consequences.........." 2.3 In this view of the matter, I hereby hold that since investment in the new house has been made outside India, the assessee has not fulfilled the basic requirement of availing the benefit under section 54 of the I.T Act, and, therefore, the benefit of deduction

DEVENDRA SINGH,ALLAHABAD vs. DCIT, RANGE-1, ALLAHABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 67/ALLD/2023[2011-12]Status: DisposedITAT Allahabad05 Sept 2023AY 2011-12

Bench: Shri Aby T. Varkey & Shri Ramit Kocharassessment Year: 2011-12 Mr. Devendra Singh, The Deputy Commissioner Of 166A, Puravaldi Kydganj, V. Income Tax, Range-1, Allahabad, Allahabad-211003,U.P. U.P. Pan:Aexps6329H (Appellant) (Respondent) Assessee By: None Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 04.09.2023 Date Of Pronouncement: 05.09.2023 O R D E R

For Appellant: NoneFor Respondent: Sh. A.K. Singh, Sr. DR
Section 139Section 143Section 143(3)Section 147Section 148Section 54Section 54F

property was made from undisclosed sources as alleged hence the addition made on conjecture and surmises by then assessing officer is highly unjustified. 7. That in any view of the matter interest charge under different section by assessing officer is highly unjustified.” 3. The brief facts of the case are that the assessee filed his original return of income

AHMAD HUSSAIN KHAN,,MIRZAPUR vs. ITO,, MIRZAPUR

ITA 544/ALLD/2014[2009-10]Status: DisposedITAT Allahabad11 Nov 2021AY 2009-10

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Sh.VinayGoel,C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143(3)

properties which was otherwise allowable while telescoping the addition made to the extent of Rs. 21,82,000.00. 14. Because without prejudice to the above grounds of appeal, Sec. 68 does not apply to the facts of the appellant since for applicability of Section 68, the amount should be found credited in the books of accounts of the appellant

DHIRENDRA SINGH,MIRZAPUR vs. INCOME TAX OFFICER, WARD- 3(1), MIRZAPUR

In the result, the appeal of the assessee is partly allowed

ITA 133/ALLD/2024[2015-16]Status: DisposedITAT Allahabad20 Mar 2025AY 2015-16

Bench: Shri Subhash Malguria & Shri Nikhil Choudharyassessment Year: 2015-16 Dhirendra Singh V. Income Tax Officer Mangraha, Chunar Ward 3(1) Mirzapur Mirzapur Pan:Bipps5569C (Appellant) (Respondent) Appellant By: Shri Brij Bhushan Goenka, C.A. Respondent By: Shri A. K. Singh, Sr. D.R. Date Of Hearing: 02 01 2025 Date Of Pronouncement: 20 03 2025

For Appellant: Shri Brij Bhushan Goenka, C.AFor Respondent: Shri A. K. Singh, Sr. D.R
Section 142(1)Section 143Section 143(2)Section 250Section 69A

House (9000 sq. ft.). It was being run by the assessee in rented premises of his mother, Smt. Sita Devi since 01.10.2013. This year, the same was taken as a gift from mother and introduced in the capital. Papers in this regard were attached. Finally, it was submitted that Rs.5.25 lakhs had been received as gifts in cash from four

KAMLA DEVI,,ALLAHABAD vs. JT.CIT,, ALLAHABAD

ITA 572/ALLD/2014[2010-11]Status: DisposedITAT Allahabad07 Mar 2023AY 2010-11

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2010-11 V. Joint Commissioner Of Smt. Parvati Devi L/H Late Kamla Devi, Sahson, Allahabad, Income Tax, Central Circle, Allahabad U.P. Pan-Bfrpd6086G (Appellant) (Respondent) Assessee By: None (Application) Respondent By: Sh. Rabin Chaudhari, Cit Dr Date Of Hearing: 23.01.2023 Date Of Pronouncement: 07.03.2023 O R D E R

For Appellant: None (Application)For Respondent: Sh. Rabin Chaudhari, CIT DR
Section 132Section 143(3)Section 154Section 69

section 143(3) of the Income Tax Act for last so many years wherein the assessee has been declaring the income ranging from Rs. 18 to 28 lacs. Therefore, the availability of cash of Rs. 6,70,000/- was not abnormal or excess in view of the past income declared by the assessee. He has thus pleaded that the addition