2025 (9) TMI 629

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....4. The impugned order was emanated from the order of the Learned Commissioner of Income-tax, Circle 19(3), Mumbai (for brevity the Ld. AO), order passed under section 143(3) of the Act, date of order 24/12/2019. 2. The brief facts of the case are that the assessee's case was selected for scrutiny under CASS. The assessee is engaged in business of trading and manufacturing in gold, diamond jewellery and has dealt in number of items as per specific action of customers. During the impugned assessment year, the assessee deposited cash amount to Rs. 3,67,06,700/- in various bank accounts between 09/11/2016 to 30/12/2016 as reported by the Ld.AO. During the assessment proceedings, the notice under section 142(1) of the Act was issued and assesse....

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....ash sales figures of the preceding years as the assessee had come up with various incentives and offers on small gold coins / jewellery during Diwali and taken strategical decision to develop with retails counter in a big way by sale of smaller items which resulted in a boost of cash sales for the year under consideration. In support of the above claims the assessee also submitted that the cash balance accounted as per the cash book of the assessee was having cash balance as on 31-03-2016/01-04-2016 of Rs. 43,05,854/- as per the audited financials. The assessee maintains on average cash-in-hand balance of appx 40 lakhs to 50 lakhs at any point of time. The cash balance accounted as per the cash book of the assessee as on 30-09-2016 is amoun....

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....of sales for the month of October 2016 were in continuous number for all type of sales i.e. Cash sales, credit sales and also sales by credit cards. The total sales in October 2016 were Rs. 12,37,16,956/-. Out of the same Rs. 2,94,91,965/- were cash sales and Rs. 2,62,094/- were credit card sales and balance credit sales of Rs. 9,39,62,897/- 6. The Ld.AR argued and stated that evidence was submitted before the Ld.AO and the Ld.CIT(A). Further, the documents were submitted through the paper book containing pages 1 to 1088. The list of documents is reproduced as below: - Sr.No. Particulars APB Page No. 1. Letter dated 22-08-2018 filed online on 22-08-2018 before the AO against notice dated 17-08-2018 issued u/s 143(2) of the Act during ....

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....ck Register of Gold Coins, Stock books of Golds, Diamond Jewellery Register, 14KT Diamond Jewellery Register, Jadav Ornaments Register reflecting the quantity of Opening balance, receipts during the year, issued during the year and closing balance for various items for the FY-2016-17 vide Annexure-4 of the said letter. * Copies of Tax invoices for the FY-2016-17 vide Annexure-5 of the said letter. * Statement of Reconciliation of an amount of Sales and Purchases as per Profit and Loss Account viz-a-viz as per VAT return along with the copy of Quarterly VAT returns vide Annexure-6 of the said letter. 362-892 7. We have heard the rival submissions and examined the documents available on record. The Ld. AO presumed, without any corrobora....