2023 (6) TMI 1448

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..... 2. The only issue in this appeal of assessee is as regards to the order of CIT(A) confirming the action of the AO in making addition of specified bank notes deposited during demonetization period being not a legal tender u/s. 69A of the Act amounting to Rs. 16.20 lakhs and taxed u/s.115BBE of the Act. For this, assessee has raised various grounds, which need not be reproduced. 3. Brief facts are that the assessee is an individual and engaged in retail / wholesale of egg business in the name and style of 'Arav Tradings'. The assessee is having savings bank A/c. No. 1666101011943, OD A/c No.16662850000005 and CC A/c. No.16662140000001 with the Canara Bank, Namakkal and also having SB A/c. No.752053000001233 with the South Indian Bank,....

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....Act, 1934, are very relevant. Section 17 of RBI Act says that making and issue of bank notes shall be one of the business of Reserve Bank of India. As per section 22 of RBI Act, RBI shall have the sole right to issue bank notes. Section 26 says that subject to sub-section (2) of Sec.26, every bank notes shall be a legal tender in any place in India in payment for the amount expressed therein and it shall be guaranteed by the Central Government. While sub-section (2) says that Central Government on the recommendation of Central Board (it is board of RBI directors) by notification in Gazette of India may declared any series of bank notes will cease to be legal tender from the date as noticed in Gazette and term as specified in the notificatio....