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ITAT allowed the appeal of the assessee, holding that additions under section 69A read with section 115BBE based solely on bank cash deposits were unsustainable where the assessee had declared income under presumptive taxation u/s 44AD and was not obliged to maintain detailed books. The Tribunal accepted contemporaneous cash-flow statements, month-wise cash sales and deposit analyses, and comparative business trends showing proportionate growth and heightened cash activity surrounding demonetisation. Given the jewellery-trading nature in a rural area with limited digital infrastructure and absence of any specific incriminating material from the Revenue disproving the explanations, the AO's addition was deleted and the reassessment based on unexplained cash deposits dismissed.
ITAT allowed the appeal of the assessee, holding that additions under section 69A read with section 115BBE based solely on bank cash deposits were unsustainable where the assessee had declared income under presumptive taxation u/s 44AD and was not obliged to maintain detailed books. The Tribunal accepted contemporaneous cash-flow statements, month-wise cash sales and deposit analyses, and comparative business trends showing proportionate growth and heightened cash activity surrounding demonetisation. Given the jewellery-trading nature in a rural area with limited digital infrastructure and absence of any specific incriminating material from the Revenue disproving the explanations, the AO's addition was deleted and the reassessment based on unexplained cash deposits dismissed.
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