Just a moment...

Top
Help
AI Drafter

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

Try Now
×

By creating an account you can:

Logo TaxTMI
>
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
TMI Blog
Home / RSS

2025 (11) TMI 1133

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....017-18. 2. The first issue that arises for our consideration in the present appeal pertains to the addition made under section 69A of the Act on account of cash deposited by the assessee in its bank account during the demonetization period. 3. The brief facts of the case pertaining to this issue, as emanating from the record, are: The assessee is engaged in the business of trading of floor tiles. For the year under consideration, the assessee filed its return of income on 31.10.2017, declaring a total income of Rs. 20,72,470/-. The assessee also declared a net profit at Rs. 39,51,690/- under section 115JB of the Act. The return filed by the assessee was selected for scrutiny, and statutory notices under section 143(2) and section 142(....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....es Bank - Powai branch 3020000   In IndusInd Bank - Powai Branch 2039000   in STATE BANK OF INDIA 31000         b) Total Cash Deposit In Bank from 09-11-15 to 31-03-16     In Yes Bank - Powai branch 1384500   In IndusInd Bank - Powai Branch 1444000   In Kotal Mahindra Bank 20000       2. Total Cash Deposit in Bank in F.Y. 2016-17     IndusInd Bank 1280000   Axis Bank 6589 250000   Axis Bank 8603 1150000   Kotak Mahindra Bank 400000         a) Total Cash Deposit in Bank from 01.04.2016 0   ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... 6. The learned CIT(A), vide impugned order, dismissed the ground raised by the assessee on this issue and held that the assessee in the course of its business made cash sales to unregistered dealers in the grey market who do not provide their addresses and PAN and the assessee also failed to furnish cash book and cash sale details. Accordingly, the learned CIT(A) held that the assessee has not submitted any documentary evidence in support of its claim. Being aggrieved, the assessee is in appeal before us. 7. We have considered the submissions of both sides and perused the material available on record as per Rule 18(6) of ITAT Rules, 1963. During the hearing, reiterating the submission made by the assessee before lower authorities, t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e were only made during the period from 01.09.2016 to 08.11.2016, and the assessee did not furnish any documentary evidence to counter the claim of the AO. We further find that the learned CIT(A) dismissed the ground raised by the assessee in this regard, merely noting that the assessee failed to furnish the cash book and cash sale details. However, as noted above, these details have been placed reliance upon by the assessee before the AO during the assessment proceedings. Since these details were not considered by the learned CIT(A) while dismissing the ground raised by the assessee on this issue, we deem it appropriate to restore this issue to the file of the learned CIT(A) for de novo adjudication after considering the details filed by t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 25,00,000 29,589 5 Kothari Granite Pvt. Ltd. AAACK5482d 16.01.2017 8,00,000 27,720 6 Snow White Metal Industries AAECS5080R 20.02.2017 15,00,000 19,726 7 Shashwat Metallic Pvt. Ltd. AACCG1417G 25.01.2017 1,00,00,000 1,95,287 8 Subhkari Marketing Pvt. Ltd. AARCS2798H 16.11.2017 50,00,000 2,01,205   Total     2,58,00,000 5,44,540 11. Accordingly, the assessee was asked to furnish various details to prove the identity and creditworthiness of the loan lender and the genuineness of the transaction. However, the assessee failed to submit ledger confirmation, books of the respective parties, return of income for the assessment year 2017-....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d the addition made by the AO under section 68 of the Act. Further, the learned CIT(A) also upheld the disallowance of interest and addition on account of commission expenditure made by the AO. Being aggrieved, the assessee is in appeal before us. 13. We have considered the submission of both sides and perused the material available on record as Rule 18(6) of the ITAT Rules, 1963. During the hearing, by referring to the separate paper book filed by the assessee, the learned AR submitted that the assessee obtained all the information as sought by the lower authorities, however, none of these details were considered while making the impugned addition. As noted above, the learned CIT(A) also did not consider the details as referred to by th....