TaxTMI 
TaxTMI 
TaxTMI 
2025 (11) TMI 324
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....d trading of cotton. The return of income for the A.Y. 2017-18 was filed on 07.10.2017 declaring total income of Rs. 10,19,670/-. The case was selected for scrutiny under CASS. The Assessing Officer found that the assessee had made cash deposit of Rs. 3,50,10,500/- during the demonetisation period from 8th November, 2016 to 30th December, 2016 in specified bank notes. The Assessing Officer found that the assessee had made cash sales of Rs. 156.96 Lakhs during the period from 01.04.2017 to 08.11.2017 whereas cash sales of Rs. 69.86 Lakhs only was made in the corresponding period of F.Y. 2016-17. The Assessing Officer was not convinced with the explanation of the cash deposits in the bank account of the assessee. He, therefore, treated the en....
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....d details as per audit report & there was a discrepancy in Khol sales/outwards as mentioned in monthly stock movement summary and submission made during remand proceedings. (b) The appellant craves leave to add, alter and/or to amend all or any the ground before the final hearing of the appeal." 5. Shri Hargovind Singh, the Ld. Sr. DR submitted that there were discrepancies in the cash book submitted by the assessee company during enquiry before the Investigation Wing and during the assessment proceedings and various other discrepancies were also noticed in the copy of invoice, weigh bridge receipts and the delivery challans etc. submitted during the course of assessment proceeding. He further stated that the assessee had failed....
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....find any rationale to treat the entire cash sales of the assessee during this period as bogus. It is not that the assessee had shown cash sales only during the current year. The Assessing Officer had admitted in his order that the cash sales were made in the corresponding period of the preceding year as well. It is true that the cash sales during the year was much higher than the cash sales during the corresponding period of the earlier year. But, this cannot be taken as a basis to disallow the entire cash sales of the current year as bogus. In fact, the total sales of the assessee during the year was also much higher at Rs. 91.03 crores as against sales of Rs. 59.52 crores only in the preceding year. The Assessing Officer has referred to d....
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....s the appellant's submissions before the assessing officer, which are available in the e-proceeding on the e-filing portal/CPC 2.0. 5.1. The appellant submitted that the addition of Rs. 1,56,96,312 under section 68 as unexplained cash is essentially cash sales made by the appellant, which is an item on the trading account and not on the balance sheet where section 68 could be applied. The appellant further contended that these cash sales were duly credited in the sales account and included in the profit disclosed by the appellant. Therefore, the same cannot be treated as undisclosed or unexplained income, referring to the decision of the Honourable Delhi High Court in the case of CIT vs Kailash Jewellery House, ITA No.613 of 20....
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....ient stock of Khol and whether the sale price was in line with market rates. 5.4. The assessing officer was requested to inquire into this matter. The remand report indicates that the appellant had a sufficient quantity of Khol for sale, and the appellant's business could produce such a quantity of Khol output from cotton processing. Additionally, the sale prices on the invoices were consistent with market trends. The report also notes discrepancies in the quantum of raw cotton and cotton bales between the appellant's submission before the assessing officer and the audit report. The assessing officer identified a discrepancy in the average purchase price during the financial year 2015-16, finding it below the selling price.....