2026 (1) TMI 67

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 2. Brief facts of the case are, assessee filed its return of income on 21.11.2017 declaring total income of Rs. 6,16,930/-. The case was selected for complete scrutiny through CASS for the following reason :- "abnormal increase in cash deposits during demonetization period as compared to pre-demonetization period." 3. Notices under section 143(2) and 142(1) of the Income-tax Act, 1961 (for short 'the Act') were issued and served on the assessee through ITBA portal. After final showcause notice issued on 07.11.2019, assessee submitted relevant information through ITBA portal. The assessee submitted that cash of Rs. 48,48,186/- was deposited in old currency in Canara Bank, Tagore Garden, Delhi Branch from 09.11.2016 to 31.12.2016....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....chases which clearly establish from the chart wherein the assessee had not given data, such as, PAN, address, etc. in respect of certain parties from where purchases were made. The Assessing Officer reproduced the details of cash deposit made by the assessee prior to demonetization period which is listed in the assessment order. He also observed that assessee has filed vouchers to justify the cash sales which are without name and address even the cash sales exceeding Rs. 25,000/-. Accordingly, he proceeded to make the addition u/s 68 of the Act. 5. Aggrieved with the above order, assessee preferred an appeal before NFAC, Delhi and filed grounds of appeal and detailed submissions along with copy of VAT returns. It was submitted that sales....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 401400 38,000.00 7976360 8,00,704.51 -1412751 January 40,76,235.44 5450741 - 2826244 2,83,711.66 1211746 February 69,84,444.09 2880000 - 1550095 1,55,605.82 2541651 March 84,69,954.91 2108780 30,000.00 6492989 6,51,796.75 -1842558 Total   5,07,34,390 8,69,837.20 57182653 413,830.227   6. After considering the above submissions, ld. CIT(A) sustained the addition made by the Assessing Officer with the observation that no satisfactory reply was furnished by the assessee. During appellate proceedings, the assessee merely stated that the deposits are out of cash sales and no documentary evidence was filed in support of the deposit. 7....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the informations are submitted before the lower authorities that considering the opening stock and purchases matches with the sales after considering the GP earned by the assessee. He relied on the detailed submissions made before the ld. CIT(A). 9. On the other hand, ld. Dr of the Revenue relied on the findings of the lower authorities. 10. Considered the rival submissions and material placed on record. We observe that the Assessing Officer proceeded to make the total cash deposit made by the assessee during demonetization period since assessee could not submit the relevant information of cash deposit made by the assessee during the impugned year. Assessing Officer also observed that when the assessee is depositing minor cash in its ....