The petitioner, is an assessee under the provisions of the Income Tax Act, 1961 (‘the IT Act’ for short). The petitioner assessee filed returns of his income for the assessment year 20212022 on 25.01.2022, declaring total income of Rs. 16,52,780/-. Petitioner is engaged in the business of commercial loan activities. The petitioner case was selected for complete scrutiny under CASS for the reason that the petitioner assessee has taken unsecured loans from such persons who have not filed their return of income. Accordingly, a notice under Section 143(2) was issued and served on the petitioner on 28.06.2022. A show cause notice has been placed on record as Exts.P1, P4 and P5, contained the chart of 22 persons from whom the petitioner had accepted deposits on extend of Rs. 1,28,08,364/-. It is also mentioned that on the confirmation of depositors, deposits details ledger and bank account, it was noticed that the assessee had taken loan from 45 lenders. Out of the 45 lenders, only 7 lenders had filed their returns of income. Remaining 38 lenders were not assessed to tax. It is also noticed from the comparison of letters filed in Form 3CD for the assessment years 2020-2021 and 2021-2022 that the assessee had received new loan from 22 parties, who were not assessed to tax and their details had
