2021 (7) TMI 362

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....e deleted in the interest of justice. 2. For that, the learned C.I.T.(A) has committed gross error of law in not deleting the entire addition of Rs. 6,31,000.00 and in reducing the addition to Rs. 4,31,200.00, made by the learned A.O., treating cash deposits made in the bank during demonetization period as unexplained income of the Appellant by applying section 69A of the Act, particularly when, the same formed part of the business turnover already disclosed, as such, the impugned addition being not sustainable in the eye of law is liable to be deleted in the interest of justice. 3. For that, the section 69A of the Act has no application under the facts and in the circumstances of the case, as such, the consequential addition of Rs. 4,3....

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....d currency i.e. specified bank notes of Rs. 6,31,000/-. When the AO required the assessee to explain the source of cash deposit, it was stated that this is normal collection from customers but could not furnish any documentary evidence. The AO did not accept the explanation of the assessee as plausible one and has passed order u/s. 144 of the Act on 39.9.2019 treating the cash deposit of Rs. 6,31,000/- as receipt from unexplained source and added the same u/s. 69A of the Act. On appeal, the Ld. CIT(A) after considering that certain amount would be available with the assessee from regular business and no deposit was done nearly 20 days prior to demonetization, allowed credit of SBN of Rs. 2,00,000/-, therefore, reduced the addition from Rs. ....