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    <title>2025 (1) TMI 1723 - ITAT CUTTACK</title>
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    <description>Whether cash deposits during the demonetization period, sourced from specified banknotes (SBN) received on retail sales, could be treated as unexplained under s. 69 was the dominant issue. The Tribunal held that the AO had accepted the declared sales, stock, and trading results and had not invoked s. 145(3) or treated the transactions as unauthorised receipts; further, in the assessee&#039;s line of business, opened bottles could not be returned, compelling acceptance of SBN to avoid total loss, constituting a reasonable and exceptional business necessity. Consequently, the s. 69 addition sustained by the CIT(A) was deleted and the appeal was allowed.</description>
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      <title>2025 (1) TMI 1723 - ITAT CUTTACK</title>
      <link>https://www.taxtmi.com/caselaws?id=465786</link>
      <description>Whether cash deposits during the demonetization period, sourced from specified banknotes (SBN) received on retail sales, could be treated as unexplained under s. 69 was the dominant issue. The Tribunal held that the AO had accepted the declared sales, stock, and trading results and had not invoked s. 145(3) or treated the transactions as unauthorised receipts; further, in the assessee&#039;s line of business, opened bottles could not be returned, compelling acceptance of SBN to avoid total loss, constituting a reasonable and exceptional business necessity. Consequently, the s. 69 addition sustained by the CIT(A) was deleted and the appeal was allowed.</description>
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