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Issues: Whether cash deposits made during the demonetisation period could be treated as unexplained money under section 69A of the Income-tax Act, 1961 and taxed under section 115BBE, when the assessee claimed that the deposits represented realisation of sundry debtors reflected in earlier books and returns.
Analysis: The assessee had maintained books of account, filed earlier returns and financial statements before demonetisation, and produced a cash book showing date-wise receipts from debtors. The source of the deposits was traced to realisation of sundry debtors appearing in the balance sheet, and the explanation was found to be supported by contemporaneous records. It was also noted that deposits of specified bank notes could be made up to 31.12.2016, and the facts did not justify treating the deposits as unexplained merely because they were made in the demonetisation period.
Conclusion: The addition under section 69A and the consequential taxation under section 115BBE were held to be unsustainable, and the relief was granted in favour of the assessee.
Final Conclusion: Cash deposits were accepted as explained from disclosed sources, and the assessment addition was deleted.
Ratio Decidendi: Where cash deposits are supported by books of account, earlier returns and contemporaneous evidence showing realisation of disclosed sundry debtors, they cannot be assessed as unexplained money under section 69A of the Income-tax Act, 1961.