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2024 (5) TMI 32

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.... of the case are that appellant assessee filed income tax return for the assessment year 2017-18 on 14th October, 2017 declaring income of Rs. 32,89,510/-. The case was selected for scrutiny under CASS and notice dated 24.09.2018 under section 143(2) was issued. Learned ACIT ("AO") passed assessment order under section 143(3) of the Act made disallowance of Rs. 65,49,189/- under section 69A read with section 115BBE of the Act on allegation that assessee failed to establish that the cash deposited during demonetisation period was as part of the normal business receipts. 3. Assessee preferred an appeal before the Learned CIT(A) on 13.01.2020. Learned CIT(A) vide order dated 31.03.2023 upheld disallowance made by the AO. 4. Being aggrieved a....

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....2016-17 37,19,652.10 58.98 21,94,04,378 AY 2017-18 40,66,442.20 64.25 26,12,88,548 The assessee had further tabulated the difference arising out of difference in average per unit price for both years and difference in volume sold in each in the table below:- Description Amount(INR) Difference arising only due to difference in average/unit price of petrol, speed petrol and diesel 37,29,298 Difference arising only due to increase in volume of petrol, speed petrol and diesel sold 26,89,170 Others (including lubricant sold etc.) 1,30,721 Addition made by the AO under Section 69A 65,49,189 6. The table showed that the quantity purchased during 2017- 18 was higher than purchased in 2016-17. The said purchase for AY 2017-18 was ....