2025 (5) TMI 885

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....me at Rs. 24,43,510/-. The case of the Assessee was selected for scrutiny, an assessment order came to be passed u/s 143(3) of the Income Tax Act, 1961 ('Act' for short) by making an addition of Rs. 56,00,000/-on account of unexplained money u/s 69A of the Act. Aggrieved by the assessment order dated 31/12/2019, the Assessee preferred an Appeal before the Ld. CIT (A). The Ld. CIT(A) vide order dated 18/04/2023, dismissed the Appeal filed by the Assessee by confirming the addition made by the A.O. As against the order of the Ld. CIT(A), the Assessee preferred the present appeal. The Ld. Assessee's Representative submitted that the Assessee is not pressing the Ground regarding the DIN, accordingly additional Ground of appeal regarding the....

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....on two dates i.e. 05/11/2016 and 06/11/2016 which is just before demonetization date i.e 08/11/2016. The Assessee recorded sales of silver goods and the value of the each of the bills were above 90,00,000/- and below to Rs. 1,00,000/-. Ld. Department's Representative drawing attention to the 59 invoices date 05/11/2016 and 07/11/2016 submitted that at no stretch of imagination, it is possible that all the customers demanded the same quality of the silver on those two days. Further submitted that the Ld. CIT(A) has specifically given finding that the Assessee created bogus bills/invoices of cash sales wherein no name, mobile number, address, PAN Number of the parties to whom the sales were made are mentioned. The Assessee created those b....

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....of the Assessee are supported by sale bills and the availability of stock which are duly reflected in the stock register maintained by the Assessee Company. The Revenue Authorities have not disputed the availability of stock at any point of time. Apart from the same, it is found that the cash sale for the year under consideration is much less than the cash sales and cash deposits made for the Assessment Year 2016-17. The said details are as under:- A.Y Cash sales Cash Deposit 2016-17 Rs. 21,03,97,670 21,07,78,000 2017-18 1,02,73,800 Rs.96,00,000 6. The Ld. Departmental Representative submitted that, the above comparison of the year under consideration i.e. 2017-18 and 2016-17 will go against the Assessee as the....