TaxTMI 
TaxTMI 
2025 (6) TMI 943
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....e that assessee is a private limited company and is a NBFC duly registered with RBI. The return of income was filed on 30.10.2017 declaring total income at Rs. 20,21,550/-. The assessment was taken up for complete scrutiny by way of issue of notice u/s 143(2) of the Act. The reason for scrutiny were 1. High value receipt of cash from third parties in response data and 2. Large value cash deposit during the demonetization period reported. The assessee has deposited total cash in SBN of Rs. 2,06,50,000/- on two bank accounts (Rs. 1,03,44,000/- in City Union ank A/c No. 512120020000876 and Rs. 1,03,06,000/- in City Union Bank in A/c No. 102109000067620). During the course of assessment proceedings various quarries were raised with regard to th....
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.... which clearly established that assessee was having only two days receipts of instalments on 08.11.2016 when demonetization was announced, thus deposit of cash in SBN of Rs. 2,06,50,000/- is not justifiable. Regarding the contention of the assessee that it has large cash balance available, ld. Sr. DR drew our attention to the fact that assessee is a NBFC and as per the RBI guideline, it can disburse the loan through banking channel only thus there is no requirement to keep such a large cash balance. At the most some cash could be held for day to day expenditure. 5. Ld. Sr. DR further submitted that assessee has made deposit on various dates during the demonetization which is quite surprising as when the assessee was having cash balance on ....
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.... was mentioned, such as their name, addresses, vehicle no, amount received etc. Ld. AR thus submitted that assessee has duly discharged the burden casted upon it of establishing the source of the cash deposits which was duly appreciated by ld. CIT(A) while deleting the addition made on this account. Accordingly, ld.AR prayed for the confirmation of the order of the ld. CIT(A). 7. We have heard the rival submissions and perused the materials available on record. In the instant case, the books of accounts of the assessee are subject to audit and from the perusal of the financial statements, we find that neither the auditor has pointed out any deficiency in the maintenance of the books of accounts nor the Assessing Officer has pointed out any....