2025 (9) TMI 789

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.... Shri Ganesh R Ghale, Advocate, Standing Counsel for Revenue ORDER PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the order passed by the NFAC, New Delhi vide order dated 20-03-2025 in DIN No.ITBA/NFAC/S/250/2024-25/1074783431(1) for the assessment year 2017-18. 2. The present appeal is filed by the assessee against the order of the learned Commiss....

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....e learned Authorised Representative (AR) of the assessee argued that there were sufficient cash withdrawals from the bank prior to demonetisation. These withdrawals were used for making the cash deposits during the demonetisation period. The AO himself has recorded in his order that the assessee made cash withdrawals. Therefore, the cash deposits cannot be treated as unexplained under section 69A ....

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....hifts to the Revenue to disprove it with evidence. No such evidence has been brought on record. 7.1 It is true that a prudent person normally does not withdraw large sums only to keep them idle at home. But this reasoning alone cannot be a ground to make an adverse inference against the assessee. The law requires the Revenue to show positive material that the withdrawals were spent otherwise. I....