2025 (6) TMI 58

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.... Department : Shri Rajesh Tiwari, Sr. DR ORDER PER NAVEEN CHANDRA, AM :- This appeal by the assessee is directed against the order of the ld. NFAC, Delhi dated 16.02.2024 for A.Y 2017-18. 2. At the very outset, the ld. counsel for the assessee submitted that a petition for admission of additional ground of appeal has been filed which reads as under: "That the provisions of sec....

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....ction 115BBE is applicable only from A.Y 2018- 19. 4. The fact of the matter in the instant case is the cash deposits during the period of demonetization added u/s 68 of the Income Tax Act. The AO has sought to tax the cash deposited in the bank of Rs. 33,75,933/- which is stated to be out of withdrawals and cash deposited out of disclosure under IDS 2016, invoking the provisions of section 115....

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.... be accepted in entirety especially when the AO found negative cash balance in the cash book. On the other hand, the Revenue's endeavour to disbelieve the assessee's contention that cash deposit has been made out of sales and disclosure under IDS scheme, cannot be fully justified. In this factual matrix, there is some element of failure to explain some of the cash deposit, cannot be ruled out. Be ....