2023 (12) TMI 1426

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.... Upadhyay, CA For the Department : Shri Vivek Vardhan, Sr. DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- This appeal by the Revenue is preferred against the order of the CIT[A]- 27, New Delhi dated 28.02.2023 pertaining to Assessment Year 2017-18. 2. The sum and substance of the grievance of the Revenue is that the ld. CIT(A) erred in deleting the addition of Rs. 1,59,26,716/- on ....

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....1,94,89,000/- was in Specified Bank Notes and Rs. 1,54,00,000/- in other denomination notes during the demonetization period, The Assessing Officer further observed that there is an increase in cash sales of more than 68% in F.Y. 2016-17 as compared to F.Y. 2015-16. 5. After perusing the month-wise details of cash sales, vis a vis cash deposits, the Assessing Officer came to the conclusion that....

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....ad of Rs. 1,22,21,293/- as shown by the assessee and went on to treat the excess amount of Rs. 1,59,26,716/- as unexplained and made addition of the same u/s 68 of the Act. 8. We are of the considered view that the mathematical calculation of the Assessing Officer is simple mathematics and has nothing to do with the actual figures recorded in the books of account during the year under considera....

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.... 19 24.09.2016 2183396 20 14.10.2016 2332094 21 15.10.2016 2344011 22 18.10.2016 2232099   10. From the above chart, it can be seen that the cash sales is always more than Rs. 20 lakhs per day which went as high as Rs. 45.55 lakhs. The total sales from 28.08.2016 to 03.09.2016 is Rs. 1,30,42,002/- which means that cash sales of 8 days are more than cash s....