2024 (3) TMI 1441

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.... ORDER PER SATBEER SINGH GODARA, J.M. : This assessee's appeal for assessment year 2017-18, arises against the National Faceless Appeal Centre [in short the "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/250/2023-24/1058255764(1), dated 28.11.2023, involving proceedings u/s. 143(3) of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties. Case file perused. 2. Co....

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....AO has also stated that the calculation based on goods received inwards and goods sent outward leads to a higher GP than the GP declared by the appellant. The appellant in this regard has given clarification to the AO vide reply dated 26.11.2016. On perusal of the said reply (as reproduced in the assessment order) it is noted that the appellant has provided due explanation reconciling the discrepa....

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....had this been the correct position the appellant would have brought this to the notice of the department in his reply furnished on the window opened in e-filling portal 'Cash Transaction 2016' after the demonetization period. In the said window the appellant replied that the entire amount deposited relates to the regular business activity of the appellant. This very fact indicates that the explana....

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....the test of evidence as the family members are the parties closely related to the appellant. Thus, the cash deposited in SBN during the demonetization period of Rs. 11,19,000/- claimed to be pertaining to family members is held to be the unexplained money of the appellant himself. Accordingly, the addition of Rs. 11,19,000/- is upheld. The Ground of appeal raised is partly allowed." 3....