2025 (11) TMI 220

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....y the AO u/s. 68 of Rs. 31,10,500, 2. The brief facts of the case show that assessee is a co-operative society, filed its return of income on 7.11.2017 at a total income of Nil wherein deduction u/s. 80P(2)(a)(i) of the Act of Rs. 8,58,800 was claimed. The case of the assessee was selected for scrutiny on account of high value receipt of cash shown from 3rd parties. Notice u/s. 143(2) was issued on 11.8.2018. In response to the notice, the assessee furnished P&L account, balance sheet, registration certificate, computation of total income, details of regular members and details of interest earned, etc. Assessee also furnish the day books and also the cash deposited during the demonetisation period along with the list of members who depos....

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.... the addition. The assessee is in appeal before me. 6. The assessee submits that the only dispute in this appeal is the addition of Rs. 31,10,500 u/s. 68 of the Act as unexplained cash credit. Ground Nos.2 to 7 are on this aspect only. It was submitted that assessee is a cooperative society which has deposited cash during the demonetisation period amounting to Rs. 31,10,500 with 3 banks. The same have been added by the AO as unexplained income u/s. 68 of the Act. She submitted that the amount is recorded in the books of account as collected members etc. The assessee has filed complete details of copy of cash book, details of cash receipt, deposit and withdrawals in the required proforma. This is in old currency notes which is collected f....

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....The funds were from the books of the cooperative society. To support the same the assessee has furnished the details of cash balance, copy of cash book, details of cash receipt, deposits and withdrawals in the proforma as desired by the ld. AO. The assessee also submitted that collection of small deposits from members in cash and collection of cash loan against recovery were deposited to the bank accounts during the demonetisation period. To support this contention, assessee also furnished a list of members from whom the SBNs have been accepted and the same were deposited. The ld. AO has merely on the basis that when the assessee was not authorised to collect SBNs and same were deposited in the bank account of the assessee with 3 other bank....