Issues: Whether the matter required remand for fresh verification of Cenvat credit taken on imported consignments and input services, and whether the documentary verification already on record was sufficient to sustain the credit.

Analysis: The disputed credit related to imported consignments supported by Bills of Entry and to input service credit distributed through the assessee's head office and regional offices. The record included the Range Superintendent's verification report, which stated that the disputed CVD amount tallied with the credit availed and that the relevant Bills of Entry were verified with the original records, including cases where manual processing had been permitted due to system issues. The report also supported the availability of credit on the input service side, with the assessee's establishments functioning as registered input service distributors and issuing invoices in accordance with the service tax rules. In view of this prior verification, the Tribunal found no justification for sending the matter back for denovo adjudication.

Conclusion: Remand was not warranted, and the credit dispute was resolved in favour of the assessee.

Final Conclusion: The impugned order directing remand was set aside and the appeal was allowed with eligibility to consequential relief in accordance with law.

Ratio Decidendi: Where the relevant documentary evidence has already been verified and supports the credit availed, a further remand for fresh verification is unnecessary.

Issues: (i) Whether the appellate order confirming attachment under the Prevention of Money Laundering Act, 2002 warranted interference, including the challenge to attachment of properties acquired prior to the Act.

Analysis: The challenge was directed against the Tribunal's final order confirming the provisional attachment of properties alleged to be derived from proceeds of crime arising out of scheduled offences. The record reflected that the Enforcement Directorate had examined the material, recorded statements under Section 50 of the Prevention of Money Laundering Act, 2002, and formed a view that the properties represented illicit gains reinvested in immovable assets and related acquisitions. The Court found that the Tribunal had already considered the grounds raised, including the objection based on the date of acquisition of properties, and that no substantial question of law, perversity, illegality, or misappreciation of evidence was shown.

Conclusion: The challenge failed and the appellate order confirming attachment was sustained.

Issues: (i) Whether the reassessment proceedings were vitiated for non-service of notice under section 148 and lack of jurisdiction; (ii) Whether the initiation and approval for reassessment were invalid for being based on incorrect facts and without application of mind; (iii) Whether the assessment on merits could be sustained when the assessee had already disclosed the property transaction and related capital gains in the original return.

Issue (i): Whether the reassessment proceedings were vitiated for non-service of notice under section 148 and lack of jurisdiction.

Analysis: The notice under section 148 was stated to have been sent to the address of the sold property, while the assessee's return records and PAN-linked details reflected a different address. The record also did not show effective service of the statutory notice. Since service of the notice initiating reassessment is a jurisdictional requirement, absence of such service goes to the root of the proceedings.

Conclusion: The reassessment proceedings were held to be without jurisdiction for want of service of notice under section 148 of the Income-tax Act, 1961.

Issue (ii): Whether the initiation and approval for reassessment were invalid for being based on incorrect facts and without application of mind.

Analysis: The reassessment was triggered on AIR information treating the assessee as a non-PAN holder and assuming non-filing of return, although the assessee had filed the original return and disclosed the property transaction, capital gains particulars, and exemption claim. On the material placed, the foundation for belief that income had escaped assessment was factually unsound, and the approval for reopening was also not shown to be the product of an informed and independent examination of the material.

Conclusion: The initiation of reassessment and the approval under section 151 of the Income-tax Act, 1961 were held invalid.

Issue (iii): Whether the assessment on merits could be sustained when the assessee had already disclosed the property transaction and related capital gains in the original return.

Analysis: The original return disclosed the transfer of the house property, the cost figures, the capital gains computation, and the claim under section 54. The Departmental record also acknowledged filing of the return. In these circumstances, there was no escapement of income warranting reassessment, and the addition sustained in the reopened assessment could not stand.

Conclusion: The assessment on merits was not sustainable, as the disclosed return already covered the transaction and no escapement of income was established.

Final Conclusion: The reassessment and the consequential assessment were set aside, and the assessee succeeded on the jurisdictional as well as merits-based challenges.

Ratio Decidendi: Service of the notice initiating reassessment is a jurisdictional prerequisite, and reassessment cannot be sustained where it is founded on incorrect facts despite disclosure of the relevant transaction in the original return.

Issues: Whether TDS deducted in the name of the deceased husband could be granted to the assessee who had offered the corresponding income in her return and whose late husband's PAN had been surrendered.

Analysis: The assessee was accepted on the Income-tax portal as the legal heir of the deceased husband. The record showed that the deceased's PAN had been surrendered and that the assessee had returned the income arising from the deceased husband's professional receipts. In these circumstances, refusing TDS credit merely because the deduction appeared under the deceased husband's PAN, while taxing the corresponding income in the assessee's hands, was found to be contrary to law and inconsistent with Article 265 of the Constitution of India. The requirement of filing a separate return in the capacity of legal heir did not arise on these facts.

Conclusion: The TDS credit was directed to be granted to the assessee, with consequential refund and interest, and the objection based on the absence of a legal-heir return was rejected.

Issues: Whether the assessee's claim for exemption under section 10(23C)(vi) required reconsideration in view of the subsequent approval granted for the relevant assessment year.

Analysis: The assessee produced an approval order granting exemption under section 10(23C)(vi) with effect from the relevant assessment year, and that approval was available before the Tribunal when the appeal was heard. The Tribunal found that the appellate order had been passed without considering this later development, which directly affected the basis on which exemption had been denied. In these circumstances, the matter required reconsideration by the first appellate authority in accordance with law.

Conclusion: The issue was restored to the CIT(A) for fresh consideration of the exemption claim under section 10(23C)(vi), and the assessee succeeded to that extent.

Issues: (i) Whether the transactional net margin method could be applied to benchmark the assessee's project-office transactions routed through joint ventures, or whether the comparable uncontrolled price method was the appropriate method; (ii) Whether reimbursements, capital contributions, mobilization advances, and receipts linked to interim payment certificates or variation adjustments were exigible to transfer pricing adjustment as international transactions.

Issue (i): Whether the transactional net margin method could be applied to benchmark the assessee's project-office transactions routed through joint ventures, or whether the comparable uncontrolled price method was the appropriate method.

Analysis: The project arrangements were found to be back-to-back construction contracts in which the joint ventures acted as administrative and routing vehicles, while the actual work, assets, and risks were borne by the project office to the extent of work allocated to it. The record showed that the contract price and work allocation were already fixed, the receipts passed through the joint ventures without value addition, and the comparable uncontrolled price reflected the same transaction economics as the controlled transaction. The transfer pricing analysis based on enterprise-wide characterisation and transactional recharacterisation was rejected in favour of a transaction-specific comparison.

Conclusion: The transactional net margin method was wrongly applied and the comparable uncontrolled price method was the correct benchmark, in favour of the assessee.

Issue (ii): Whether reimbursements, capital contributions, mobilization advances, and receipts linked to interim payment certificates or variation adjustments were exigible to transfer pricing adjustment as international transactions.

Analysis: The Tribunal accepted that reimbursement items were cost-to-cost pass-throughs without service element or markup, capital infusions and mobilization advances were capital or working-fund movements, and the variation-adjustment and interim-payment flows were routed through the joint ventures merely for administrative convenience. It was also found that the relevant project receipts were already offered to tax in India and that there was no realistic scope for profit shifting outside India on the facts of the case. The transfer pricing adjustment was therefore not sustainable on these items.

Conclusion: These items did not warrant transfer pricing adjustment, in favour of the assessee.

Final Conclusion: The revenue's challenge to the deletion of the transfer pricing adjustment failed, and the assessee's benchmarking approach and characterization of the disputed flows were sustained.

Ratio Decidendi: In a back-to-back construction arrangement where the joint venture is only a routing or administrative conduit and the controlled transaction mirrors the uncontrolled transaction, CUP is the preferred method and cost-to-cost, capital, and pass-through flows without service value addition do not justify a transfer pricing adjustment.

Issues: Whether the disallowance of provision for expenses deleted by the first appellate authority was sustainable when the evidences relied upon were not before the Assessing Officer and no remand report was obtained.

Analysis: The dispute turned on a provision for expenses claimed to have been made against later-received invoices, while the Assessing Officer had treated the amount as contingent and unascertained. The appellate record showed that invoices, ledger extracts, TDS details, bank statements and contract copies relied upon for relief were not part of the material before the Assessing Officer. Such materials amounted to fresh evidence, and their admission without obtaining the Assessing Officer's comments contravened the procedure governing additional evidence. The assessee had also not fully substantiated the entire expenditure claimed before the Assessing Officer.

Conclusion: The deletion of the addition could not be sustained, and the matter was required to be set aside to the jurisdictional Assessing Officer for fresh verification and adjudication.

Final Conclusion: The dispute was remanded for fresh examination, with the revenue's appeal succeeding only for statistical purposes.

Ratio Decidendi: Additional evidence relied upon for granting relief to an assessee cannot be accepted without following the mandated procedure of confronting it to the Assessing Officer and obtaining a remand report where required.

Issues: Whether the additions relating to cash deposits, agricultural income, unsecured loan and gift were liable to be sustained, or whether the matter required restoration to the Assessing Officer for fresh verification.

Analysis: The assessee had produced additional material before the appellate authority to explain the cash deposits as business receipts, the agricultural income by reference to land holding and produce details, the unsecured loan by a confirmation from the lender carrying a Permanent Account Number and income-tax status, and the gift by reference to the family relationship and supporting material. The appellate authority forwarded the additional evidence for a remand report, but no report was received. In such circumstances, the evidentiary material supporting the assessee's explanation required proper examination by the Assessing Officer, and the appellate authority ought not to have finally rejected the claims without that verification.

Conclusion: The additions were not finally affirmed and the matter was restored to the Assessing Officer for fresh adjudication after verification of the assessee's explanations and supporting evidence.

Issues: Whether the Commissioner (Appeals) had power to set aside the reassessment and restore the matter for de novo adjudication when the assessment was not passed under section 144 of the Income-tax Act, 1961.

Analysis: The assessment orders for both years were passed under sections 143(3), 147 and 144B of the Income-tax Act, 1961, and not under section 144. The appellate power under section 251 to set aside and remand for fresh assessment was held to be available only where the assessment order had been made under section 144. Since that jurisdictional condition was absent, the Commissioner (Appeals) could not remand the matter to the Assessing Officer and was required to decide the appeals on merits.

Conclusion: The remand orders were unsustainable and the matters were directed to be decided by the Commissioner (Appeals) on merits; the assessee succeeded.

Issues: Whether the assessee was entitled to the concessional tax regime under section 115BAB despite the return being treated as invalid and a revised return being filed after the due date, when the option had already been exercised in the preceding assessment year.

Analysis: The governing provision required the option under section 115BAB to be exercised in the prescribed manner by the due date for the first return and provided that once exercised it would apply to subsequent assessment years and could not be withdrawn. The record showed that the assessee had already exercised the option in the earlier assessment year by filing Form 10-ID, and the present year was a subsequent year of claim. The denial made by treating the later return as belated did not address the statutory effect of the earlier exercise of option, and the assessee's entitlement could not be defeated on that technical basis.

Conclusion: The assessee was entitled to the benefit of section 115BAB, and the denial of the concessional tax rate was unsustainable.

Issues: Whether the reassessment proceedings under section 153C were validly initiated and sustained where the Assessing Officer's satisfaction note did not clearly link the seized material with the assessee.

Analysis: The proceedings under section 153C required a proper satisfaction note based on seized material showing that it belonged to, related to, or had a bearing on the assessee's income. The absence of such a clear nexus, coupled with the need for a non-mechanical and reasoned exercise of jurisdiction, was examined in the light of the cited jurisdictional precedents. On the facts placed before the Tribunal, the satisfaction recorded was treated as deficient and the assessee's challenge on this core issue was accepted.

Conclusion: The challenge to the validity of the proceedings on the section 153C satisfaction issue succeeded, and the corresponding grounds were allowed in favour of the assessee.

Issues: Whether the CPC could, before 01.04.2021, make a prima facie adjustment under section 143(1)(a) to deny deduction under Chapter VIA on the ground that the return was filed beyond the due date prescribed under section 139(1), and consequently disallow deduction under section 80P.

Analysis: The return for the relevant assessment year had been filed after the due date and the CPC had disallowed the deduction while processing the return. The controlling legal position applied was that the power to make such an adjustment by disallowing a Chapter VIA claim for belated filing was conferred on the CPC only by the Finance Act, 2021, with effect from 01.04.2021, through section 143(1)(a)(v). Since the impugned adjustment had been made prior to that date, the CPC lacked the authority to deny the deduction on that ground. The prior appellate order was therefore unsustainable.

Conclusion: The disallowance was without jurisdiction and the deduction under section 80P was to be allowed. The assessee succeeded on the main ground, and the alternate ground became infructuous.

Ratio Decidendi: A prima facie adjustment under section 143(1)(a)(v) disallowing a Chapter VIA deduction for belated filing cannot be made for a return processed before the provision became effective on 01.04.2021.

Issues: Whether the disallowance of purchases on the ground of alleged non-genuineness and absence of transportation evidence was justified.

Analysis: The assessee produced tax invoices, vendor registration details, ledger accounts, banking-channel payments, and other supporting documents to substantiate the purchases. The purchases were from registered dealers, sales and overall books were not rejected, and no independent material was brought by the Revenue apart from sales tax/VAT information regarding the vendors. On the facts, the Tribunal found that the assessee had discharged the onus to explain the purchases and that it was not practical or justified to insist upon production of the vendors after a long lapse of time.

Conclusion: The disallowance of purchases was deleted and the issue was decided in favour of the assessee.

Final Conclusion: The appeal succeeded and the addition made on account of disputed purchases was set aside.

Ratio Decidendi: Where purchases are supported by primary documentary evidence, payments are made through banking channels, sales are accepted, and the books are not rejected, a purchase disallowance cannot be sustained merely on third-party information or inability to produce the suppliers after a long lapse of time.

Issues: (i) Whether the disallowance of interest expenditure under Rule 8D in relation to exempt income was sustainable. (ii) Whether the proportionate disallowance of common expenses was justified, including the exclusion of stock-in-trade from the revenue base used for apportionment.

Issue (i): Whether the disallowance of interest expenditure under Rule 8D in relation to exempt income was sustainable.

Analysis: The amended Rule 8D was treated as governing the dispute, and the earlier approach under the deleted interest component of the former Rule 8D(2)(ii) was held inapplicable. The available material did not conclusively establish the utilisation of the borrowed funds, while the record also indicated fresh investments and other advances. On the facts, the interest disallowance was viewed as resting on incomplete appreciation of the utilisation of funds, warranting further verification.

Conclusion: The interest disallowance was not finally sustained and the matter was remitted to the Assessing Officer for fresh adjudication after giving the assessee an opportunity to explain the deployment of borrowed funds.

Issue (ii): Whether the proportionate disallowance of common expenses was justified, including the exclusion of stock-in-trade from the revenue base used for apportionment.

Analysis: The assessee was primarily engaged in investment activity, and the common expenditure had been identified and apportioned on a pro-rata basis. The argument that stock-in-trade should be treated as part of total revenue for the purpose of such apportionment was rejected, because stock-in-trade is not revenue and its inclusion would distort the disallowance exercise. The assessment of common expenses was therefore found to be proper.

Conclusion: The disallowance of common expenses was upheld and the assessee's challenge on this issue failed.

Final Conclusion: The appeal succeeded only in part, with the interest issue sent back for reconsideration and the disallowance of common expenses sustained.

Ratio Decidendi: Under the amended Rule 8D, disallowance must be linked to expenditure directly relatable to exempt income, while pro-rata disallowance of common expenses may be sustained on a proper factual basis and stock-in-trade cannot be treated as revenue for that computation.

Issues: (i) Whether the protective addition made in the assessee's hands under section 68 with reference to bank credits allegedly representing accommodation entries could survive when the underlying transactions with the purchaser were found to be genuine and no substantive addition was made in the purchaser's hands. (ii) Whether the ad hoc addition of commission at 1% of the total credits/deposits in the assessee's bank accounts was justified on the footing that the assessee had provided accommodation entries.

Issue (i): Whether the protective addition made in the assessee's hands under section 68 with reference to bank credits allegedly representing accommodation entries could survive when the underlying transactions with the purchaser were found to be genuine and no substantive addition was made in the purchaser's hands.

Analysis: The assessee produced audited books, bills, vouchers, bank records and ledger details showing supply of livestock to the purchaser. The transactions were cross-verified, the sales were accepted, and the purchaser's assessment did not result in a corresponding substantive addition on the alleged accommodation-entry issue. The material on record supported genuine business dealings, and the basis for treating the receipts as unexplained credits was not sustained.

Conclusion: The protective addition was not sustainable and was rightly deleted.

Issue (ii): Whether the ad hoc addition of commission at 1% of the total credits/deposits in the assessee's bank accounts was justified on the footing that the assessee had provided accommodation entries.

Analysis: The commission addition was entirely consequential to the finding that the assessee had allegedly facilitated accommodation entries. Once the underlying premise failed and the transactions were held to be genuine business transactions, there was no independent basis to estimate commission income at 1% of total credits. No comparative or factual foundation supported the estimate.

Conclusion: The commission addition was unsustainable and was rightly deleted.

Final Conclusion: The revenue's challenge failed because the disputed receipts were held to arise from genuine business transactions, and both the protective addition and the consequential commission addition were deleted.

Ratio Decidendi: A protective addition cannot stand in the absence of a sustainable substantive basis, and a consequential commission addition cannot survive once the underlying allegation of accommodation entries is rejected on facts and evidence.

Issues: Whether the deletion of additions and disallowances made on account of share capital, trade creditors, current liabilities, expenses, depreciation and warranty provisions was justified on the basis of the evidence produced before the first appellate authority and the remand proceedings.

Analysis: The assessment had been completed ex parte on the basis of non-compliance, but the assessee produced documentary evidence before the first appellate authority to explain the source and genuineness of the share capital, the trade creditors, the current liabilities, the expenses, the depreciation claim and the warranty provision. The material was forwarded to the Assessing Officer in remand, yet no adverse defect was established in the evidence, and the disallowances had been made on ad hoc or presumptive bases without specific infirmities in the records. The first appellate authority therefore accepted the explanations and deleted the additions and disallowances. The Tribunal found no infirmity in that appreciation of evidence and no reason to disturb the findings.

Conclusion: The deletions of the additions and ad hoc disallowances were upheld, and the Revenue's challenge failed.

Ratio Decidendi: Where the assessee substantiates the disputed credits and expenditures with documentary evidence and the Assessing Officer, even after remand, does not identify specific defects, additions or ad hoc disallowances based merely on non-compliance cannot be sustained.

Issues: (i) Whether incidental receipts such as processing fees, upfront fees, lead financer fees, security trustee fees, underwriting fees and letter of comfort fees formed part of profits derived from the business of providing long-term finance for deduction under section 36(1)(viii); (ii) whether loans sanctioned for a period of not less than five years ceased to qualify as long-term finance merely because they were prepaid before five years; (iii) whether, for disallowance under section 14A read with Rule 8D, only investments yielding exempt income were to be considered; (iv) whether contribution made as part of CSR obligation to an institution registered under section 80G was eligible for deduction under section 80G.

Issue (i): Whether incidental receipts such as processing fees, upfront fees, lead financer fees, security trustee fees, underwriting fees and letter of comfort fees formed part of profits derived from the business of providing long-term finance for deduction under section 36(1)(viii).

Analysis: The eligible deduction under section 36(1)(viii) depends on profits derived from the business of providing long-term finance. The receipts in question were integrally connected with loan processing, sanction, administration and disbursement, and had a direct nexus with the financing activity. The reasoning applied the distinction between income merely attributable to a business and income derived from it, and treated these receipts as arising directly from the long-term finance business.

Conclusion: The receipts were held to be part of profits derived from the long-term finance business and were eligible for deduction under section 36(1)(viii), in favour of the assessee.

Issue (ii): Whether loans sanctioned for a period of not less than five years ceased to qualify as long-term finance merely because they were prepaid before five years.

Analysis: The definition of long-term finance was applied with reference to the terms of the loan at the time of sanction, not by subsequent premature closure. Once the loan was granted on terms providing repayment over a period of not less than five years, later prepayment did not alter its character for the purpose of the deduction. The view adopted was consistent with the principle that the nature of the account is determined at inception.

Conclusion: The loans continued to qualify as long-term finance, and the Revenue's challenge was rejected, in favour of the assessee.

Issue (iii): Whether, for disallowance under section 14A read with Rule 8D, only investments yielding exempt income were to be considered.

Analysis: The disallowance mechanism under section 14A read with Rule 8D was applied by considering only those investments that actually generated exempt income. Investments that did not yield exempt income were not to be included in the average investment base for the computation. The approach followed binding jurisdictional precedent.

Conclusion: The Revenue's basis for the additional disallowance was rejected and the relief granted by the first appellate authority was sustained, in favour of the assessee.

Issue (iv): Whether contribution made as part of CSR obligation to an institution registered under section 80G was eligible for deduction under section 80G.

Analysis: CSR character by itself did not exclude a donation from deduction under section 80G where the recipient institution satisfied the statutory registration and other conditions. The contribution retained its charitable character and there was no statutory bar merely because it was made pursuant to CSR obligations. The view adopted followed the consistent tribunal line on the point.

Conclusion: The deduction under section 80G was held allowable, in favour of the assessee.

Final Conclusion: The assessee succeeded on the principal issues concerning section 36(1)(viii), section 14A read with Rule 8D, and section 80G, while the Revenue's appeals were dismissed and the consolidated relief granted below was maintained.

Ratio Decidendi: For section 36(1)(viii), income directly and integrally connected with the long-term finance activity qualifies as profits derived from that business, and the character of a loan for deduction purposes is determined by its sanctioned terms rather than by premature prepayment; for section 14A read with Rule 8D, only investments yielding exempt income enter the computation base; and CSR-linked contributions are not excluded from section 80G merely because they arise from a statutory CSR obligation.

Issues: (i) Whether the addition for alleged under-statement of rental income from the business premises by substituting an estimated fair market rent was justified. (ii) Whether the disallowance of salary paid to the assessee's son as bogus expenditure was justified.

Issue (i): Whether the addition for alleged under-statement of rental income from the business premises by substituting an estimated fair market rent was justified.

Analysis: The rental income disclosed by the assessee was compared by the Assessing Officer with rent of a similar property at a different city and on the basis of an inspector's report. The record showed that the premises were situated at Amravati, the standard rent under the municipal reckoner was far lower than the rent actually received, and no credible evidence was brought to show that the same locality fetched a higher rent. The tenant and the assessee were both taxable at the highest rate, and the disclosed rent had remained consistent.

Conclusion: The addition for under-statement of rental income was not sustainable and was deleted in favour of the assessee.

Issue (ii): Whether the disallowance of salary paid to the assessee's son as bogus expenditure was justified.

Analysis: The salary payment was examined in the context of the family-run business, the services rendered in the business at more than one location, the long-standing nature of the payment, the increase in turnover and profits, and the fact that the amount was taxed in the recipient's hands. The disallowance rested mainly on a selective reading of the recipient's statement, without addressing the overall business requirements and past conduct.

Conclusion: The salary expenditure was held to be allowable and the disallowance was deleted in favour of the assessee.

Final Conclusion: The appeal succeeded on the substantive additions and the assessee obtained relief on both disputed issues, resulting in a partial allowance of the appeal.

Ratio Decidendi: An addition for notional rental income or disallowance of related-party salary cannot be sustained without credible, locality-specific evidence and without a reasoned finding that the expenditure or rent is unreasonable in the facts of the business.

Issues: Whether the Principal Commissioner validly invoked revisionary jurisdiction under section 263 by holding the assessment order to be erroneous and prejudicial to the interest of revenue on the ground of alleged lack of inquiry.

Analysis: The assessee had placed the relevant details before the Assessing Officer during the original assessment and again during the revision proceedings. The Principal Commissioner, while noticing alleged discrepancies and other issues, did not undertake independent verification of the material already furnished and did not record clear findings showing how the assessment order was erroneous and prejudicial to the revenue. The order proceeded on suspicion that the inquiry was casual or merely a semblance of inquiry, but suspicion by itself was insufficient to sustain revision. Revision under section 263 requires a demonstrable error and prejudice, supported by independent examination, and cannot rest on a mere view that deeper inquiry ought to have been made.

Conclusion: The invocation of section 263 was unjustified and the revisional order could not be sustained.

Final Conclusion: The assessment revision was quashed and the assessee's challenge succeeded.

Ratio Decidendi: A revision under section 263 cannot be sustained unless the revisional authority itself identifies and records, on independent verification, that the assessment order is both erroneous and prejudicial to the interest of revenue; a mere allegation of inadequate inquiry or suspicion is insufficient.

Issues: Whether the addition made under section 68 on account of cash deposits during the demonetization period was sustainable when the assessee had recorded cash sales, maintained audited books of account, and showed adequate cash availability in the business accounts.

Analysis: The assessee was engaged in FMCG retail business through multiple outlets and had furnished month-wise cash flow details, bank statements, cash deposit reports, and supporting records before the Assessing Officer. The material on record showed substantial cash sales and opening cash balances, including sufficient cash availability around the demonetization period. The addition was made mainly on the basis that the deposits were not made in one go and on an inference that the cash was not available on the demonetization date. No contrary evidence was brought to show that the deposits were not sourced from recorded business receipts, and the Assessing Officer did not establish that the impugned deposits were unexplained credits.

Conclusion: The addition under section 68 was not justified and was deleted in favour of the assessee.