TaxTMI 
TaxTMI 
2023 (12) TMI 272
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.... "Issue 1: Adding of Rs. 662783 being shortage of sources for cash deposits in bank accounts of appellant as unexplained money u/s 69 A of Income Tax Act, 1961. * Appellant explained source for cash deposit in bank accounts for Rs. 66329288 against the explanation sought for Rs. 66250166/ * The source for cash deposit Rs. 66329288 was not disputed by A.O * As such the shortage of sources for cash deposit Rs. 662783 is wrong. Issue 2: Adding cash credits Rs. 20,40,000 in appellants bank accounts after 08/11/2016 in the form of SBN to the total income u/s.69 of Income Tax Act, 1961. * The Respectable Commissioner of Income Tax, Madurai- 1 was not justified while passing the order u/s. 250 of the Income Tax Act dated 26/05/202....
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....ogga. (IT A.No. 552/Bang/2022) iii) Mrs.Umamaheswari, D.No.12A, Perumal Konar Street, VPC Nagar, Coimbatore South, Coimbatore. (ITA No.527/Chny/2." 3. The brief facts of the case are that, the assessee, M/s. Amar Sparklers Factory, filed its return of income for the assessment year 2017-18 on 28.02.2019, admitting an income of Rs. 6,59,610/-. The case was selected for scrutiny to verify huge cash deposits during demonetization period and accordingly, notice u/s. 143(2) of the Income-tax Act, 1961 (hereinafter referred to as "the Act") dated 20.08.2018, was issued and duly served on the assessee. During the course of assessment proceedings, the AO obtained details of cash deposits to State Bank of India, SME Branch, Sivakasi, IDBI Bank,....
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....ppeal before the ld. CIT(A). Before the ld. CIT(A), the assessee could not adduce any additional evidence to justify source for cash deposits. Therefore, the ld. CIT(A) sustained additions made by the AO towards cash deposits u/s. 69A of the Act. Being aggrieved by the CIT(A) order, the assessee is in appeal before us. 5. The ld. Counsel for the assessee referring to page no. 3 & 4 of assessment order submitted that, the total cash deposits/transactions in bank account was estimated at Rs. 6.63 crores and as against this, the appellant has explained source for Rs. 6.56 crores. Therefore, the AO is erred in making additions towards balance amount of Rs. 6,62,783/-. He, further submitted that in so far as advance received from group concern,....
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....itted shortage of source in their cash flow statement filed before the AO. Therefore, from the above, it is undoubtedly clear that the assessee could not explain source for cash deposits to the extent of Rs. 6,62,783/- and thus, we are of the considered view that, there is no error in the reasons given by the CIT(A) to sustain additions made towards cash deposits to the tune of Rs. 6,62,783/-. In so far as addition of Rs. 20,40,000/- towards advance received from group concerns, it was an argument of the appellant that group concerns have paid advance in cash during demonetization period and deposited into IDBI bank account. In this regard, the appellant has filed necessary details including PAN nos. and confirmation letters from the group ....
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...., copy of sales tax assessment order, monthly cash deposits and credits for various periods, ledger account for purchase and other expenditure, monthly sales gross receipts, monthly purchases, details of old notes and new notes deposited during demonetization period, the day book, Cash book, ledger maintained for business, cash balance as per cash book etc. All these details were duly submitted by assessee vide reply dated 12-12-2019. The assessee also submitted month-wise cash deposits in all bank accounts, details of old notes deposited at the time of demonetization period. Pertinently, the assessee also furnished details of name, address and PAN of cash depositors who deposited cash during demonetization period. The same has been deta....