2025 (8) TMI 34

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....RDER PER MANISH AGARWAL, AM : The present appeal has been filed by the assessee against the order dated 08.10.2024 passed by Ld. Commissioner of Income Tax (A), National Faceless Appeal Centre ("NFAC"), Delhi ["Ld.CIT(A)"] in Appeal No.CIT(A), Delhi- 17/10749/2019-20 passed u/s 250 of the Income Tax Act, 1961 ["the Act"] arising from the assessment order dated 27.12.2019 passed u/s 143(3) of....

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....1,727/- asked the assessee to furnish the source of same. Before the AO, it was submitted that the cash was deposited out of realisation of sales made during the period of 01.10.2016 to 08.11.2016 that is the date when the demonetization was announced by the Hon'ble Prime Minister. He submits that the AO has accepted the trading results declared by the assessee however, had made addition of cash d....

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....cash in the month of July and other ones the cash sales was very low which is apparent from the chart at page 30 of Ld. CIT(A)'s order. However, in the month of October and November 2016 up to 08.11.2016, the assessee has claimed more than Rs. 13,57,863/- which create doubts about the claim of the assessee and therefore, he requested that the lower authority has rightly invoked the provision of se....

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....17 before us. That being the case, we are of the considered view that although the assessee has not satisfactorily discharged its onus of filing a complete reconciliation of its cash sales/cash in hands vis-à-vis the business turnover as representing cash deposits in issue, it could not be altogether denied the credit thereof in entirety as such this course of action would not be sustainabl....