Sunil Jain. v. ITD (2022) 289 Taxman 688/ 20 ITR -OL409 (Delhi)(HC)/Editorial : SLP dismissed , Sunil Jain v. ITD (2023) 459 ITR 276 /295 Taxman 10(SC)

S. 147 : Reassessment-Cash deposit in bank-Denomination-Pendency of appeal-limited scrutiny-. No question was asked in the original assessment proceedings-Reassessment notice is held to be valid. [S. 69A, 148, Art. 226]

Assessee was selected for limited scrutiny raising queries regarding cash deposit of Rs. 28.75 lakhs made by assessee during demonetisation period in Bank  Assessment order was passed making an addition of Rs. 28.75 lakhs to returned income of assessee. Assessee preferred an appeal. During pendency of appeal, revenue issued a reassessment notice on ground that assessee had failed to satisfactorily explain source of fund for cash deposit of Rs. 12.50 lakhs made by assessee in Punjab National Bank and Bank of India and  cash deposit of Rs. 12.50 lakhs was not adjudicated upon during original scrutiny proceedings, in income-tax return, assessee had only mentioned detail of cash deposited in Corporation bank account and had not mentioned cash deposits in any other bank accounts.  The assesseee challenged the reassessment notice and order disposing the objection. Dismissing the petition the Court held that reopening notice issued against assessee was justified.  (AY. 2017-18)