2025 (4) TMI 35

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ddition of cash deposits during demonetization period. 2. The Ld. CIT-DR advanced arguments and supported the findings of Ld. AO whereas Ld. AR also advanced arguments and supported the findings of Ld. CIT(A) in the impugned order. Having heard rival submissions and upon perusal of case records, the appeal is disposed off as under. The assessee being resident corporate assessee is stated to be engaged in manufacturing / trading of gold, diamond, platinum, silver jewellery / coins / utensils and trading of gold and silver bullion. The assessee e-filed its return of income on 29-10-2017 declaring income of Rs. 305.56 Lacs. Assessment Proceedings 2.1 The assessee's case was scrutinized to verify the source of cash deposit of Rs. 18.56 Crore....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... cash sales and cash deposits for the month of October and November, 2015 to this year, Ld. AO quantified estimated excess sales for Rs. 10.96 Crores and added the same as undisclosed income u/s 68 which would be taxable at higher rates as specified u/s 115BBE of the Act. The working of the same has been tabulated on Page No.8 of the order. Aggrieved, the assessee assailed the action of Ld. AO in further appeal. Appellate Proceedings 3.1 During appellate proceedings, the assessee submitted that the addition was arrived at on the basis of statistical formula only and Ld. AO resorted to various unilaterally drawn assumptions and presumptions. The assessee maintained complete books of accounts such as cash book, ledger, stock register, purch....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tock. The closing stock reduced from Rs. 11.77 Crores to Rs. 3.60 Crores on that day. All the payments regarding purchase of stock as held by the assessee was made through banking channel well before 08-11-2016. All the transactions of purchase and sales in quantity and values were duly recorded by the assessee. The Ld. AO made addition of Rs. 10.98 Crores out of cash deposit of Rs. 18.49 Crores considering it to be excess cash sales which as estimated on the basis of a formula. The Ld. AO observed that in comparison to turnover of previous years and turnover of earlier months in the same financial year, the cash sales appeared to be quite unusual and disproportionate to its regular sales in the books of accounts. However, no evidence was t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nts as well as quantitative details of stock etc. which, in fact, has been done by the assessee. These books of accounts have duly been audited under law and the same were furnished to Ld. AO during the course of assessment proceedings. The books have not been rejected and no singled effect has been pointed out in the same. The assessee has duly furnished stock register as well as cash book which would show that corresponding entry of purchase and sales was made therein and the same were duly recorded in the books of accounts. The assessee had sufficient closing cash-in-hand as on 08-11-2016 to make impugned deposits in the bank accounts. The sales are supported by sales invoices and the payment for all the purchases was made through bankin....