2022 (12) TMI 1570

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.... trading in dry fruits. For the assessment year, under dispute, the assessee filed its return of income on 27.10.2017 declaring income of Rs. 2,37,790/-. Assessee's case selected for scrutiny to examine abnormal increase in cash deposits during the demonetization period as compared to predemonetization period. After calling for and examining the details of purchase and sales relating to financial years 2015-16, 2016-17 and 2017-18 in course of assessment proceeding, the Assessing Officer noticed that the cash sales in financial year 2016-17 is 74% of the total sales compared to very less cash sales reported in financial year 2015-16 and financial year 2017-18. He further found, assessee had booked cash sales of Rs. 43,53,900/- in October, 2....

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....mitted, without rejecting the books of account the Assessing Officer cannot allege that the assessee has manipulated the cash sales. Proceeding further, he submitted, the reason for excess cash sales in the month of October and November was due to festival of Dussehra and Diwali, wherein, sale of dry fruits substantially increases. He submitted, in response to the statutory notices issued and queries raised in course of assessment proceedings, the assessee has furnished every detail including the details of purchases and sales supported by purchase and sale invoices. He submitted, without pointing out any defect in the sales and purchases or the invoices, merely on presumption and surmises the Assessing Officer has treated a part of the cas....