The case involves appeals by Ruby Singh against orders from the Ld. Commissioner of Income Tax (Appeals)-24, New Delhi, dated 31.10.2022, for assessment years 2013-14 to 2019-20. The main issue was the initiation of reassessment proceedings under Section 147/148 of the Income Tax Act and the addition of unexplained cash credits under Section 68.
Ruby Singh challenged the validity of the reassessment proceedings initiated under Section 147/148 of the Income Tax Act, arguing that there was no specific, relevant, reliable, and tangible material on record to form a ‘reason to believe’ that her income had escaped assessment. She also contended that the proceedings were initiated without valid approval under Section 151 of the Act.
The Assessing Officer (AO) initiated reassessment proceedings based on the bank statements and income tax returns of Ruby Singh and her creditors, noting substantial cash deposits in the creditors’ accounts before issuing cheques to Ruby Singh. The AO concluded that the unsecured loans were actually unaccounted cash of Ruby Singh routed through the bank accounts to disguise them as loans.
The Tribunal upheld the AO’s findings and dismissed Ruby Singh’s appeals, concluding that the initiation of reassessment proceedings was valid. The Tribunal found that the AO had sufficient material indicating the escapement of income, justifying the initiation of reassessment proceedings and the addition of unexplained cash credits under Section 68 of the Income Tax Act.
The Tribunal dismissed Ruby Singh’s appeals for all assessment years from 2013-14 to 2019-20, confirming the additions made by the AO under Section 68 of the Income Tax Act and the validity of the reassessment proceedings initiated under Section 147/148.
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