2024 (8) TMI 735

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....nt : Shri Subramanian .S, JCIT DR ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal arises out of order dated 21.10.2023 passed by NFAC, Delhi for A.Y. 2017-18 on following grounds of appeal: "1. The Order passed by Learned CIT(Appeals) is illegal, baseless and opposed to fasts of the case. 2. The learned CIT(Appeals) has erred in making an addition of Rs. 17,73,000....

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....eposited out of previous drawings from bank. The ITO issued notice u/s. 143(2) on 28.09.2018. The ITO has completed the assessment by adding entire sum of Rs. 17,73,000/- deposit during demonetization period. The Ld.AO after considering the submissions, added Rs. 17,73,000/- as unexplained money. 2.2 Aggrieved by the order of the Ld.AO, assessee preferred appeal before the Ld.CIT(A) wherein ....

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....om the depositors are to be filed by the assessee and should be verified by the Ld.AO. 6. We have carefully gone through the various standard operating procedures laid down by the central board of direct taxes issued from time to time in case of operation clean. The 1st of such instruction was issued on 21/02/2017 by instruction number 03/2017. The 2nd instruction was issued on 03/03/2017 instr....

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....ls into statistical analysis, which suggests that there is a booking of sales, which is non-existent and thereby unaccounted money of the assessee in old currency notes (SBN) have been pumped into as unaccounted money. 8. Instruction 21/02/2017 issued by the CBDT suggests some indicators towards verifying the suspicion of backdating of cash. It also suggests indicators to identify abnormal jump....