2025 (11) TMI 450

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.....1 raised by the assessee is general in nature and requires no adjudication. 3. Ground No. 2 raised by the assessee relates to confirmation of disallowance of cash amounts under section 69 of the Income Tax Act, 1961 ["Act" in short] received from its debtors in the facts and circumstances of the case. 4. Facts relating to the case are that according to the Assessing Officer, the assessee claimed recovery from debtors to an extent of Rs..23,57,000/-. The assessee furnished a list of debtors with name & addresses before the Assessing Officer. Accordingly, vide notice under section 142(1)(ii) of the Act dated 07.08.2019, the assessee was required to produce (i) financials for FY 2015-16 & 2016-17 with breakup of details of sundry debtor....

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....ther argued that out of Rs..77,75,180/- [Rs..2,56,62,811 - Rs..1,78,87,631], Rs..23,57,000/- was received in cash and the same has been deposited in the bank during the demonetization period and prayed to delete the addition. 6. The ld. DR Ms. Gouthami Manivasagam, JCIT vehemently opposed the submissions of the assessee and submits that the assessee could not furnish PAN of any of the sundry debtors either before the Assessing Officer or before the ld. CIT(A) or even before the Tribunal. She further submits that the assessee was required to produce all the parties in person or confirmation with verifiable identity/PAN/books of account or any other reliable supporting evidence to substantiate its claim of source as recovery from debtors t....

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....,62,811/- as on 31.03.2016 to Rs..1,78,87,631/- as on 31.03.2017 for the reason that the debtors had paid their balances, but no details of mode payment, etc. has been furnished by the ld. AR. It is the claim of the assessee that the assessee company was wound up in the year March, 2017 and if so, there cannot be possibly any business transaction in that mentioned period. Payment of debt by itself is a transaction through financial in nature, which need to be recorded in the ledger account. Therefore, if any person denies to have made any transaction with the assessee in FY 2016-17, it means and includes that no transaction of purchase or sale or payments were made during the said FY. In the absence of ledger account copy of the assessee or....