2025 (1) TMI 1723

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.... This is an appeal filed by the assessee against the order of the ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi, dated 30.09.2024, passed in Appeal No.CIT(A), Bhubaneswar vide DIN & Order No.ITBA/NFAC/S/250/2024-25/1069269209(1) for the assessment year 2017-2018, on the following grounds of appeal :- 1. For that order dated 30.09.2024 as passed under Section 250 of the I.T.....

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....cumstances of the case. 2. The assessee is represented by Shri P.R.Mohanty, Advocate and department is represented by Shri S.C.Mohanty, Sr. DR. 3. The only issue involved in this case with regard to addition of Rs. 10,98,000/- made u/s.69 of the Act on account of cash deposited in the bank during demonetization period under SBN. 4. It was submitted by the Id. AR that the cash was deposite....

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....eclared by the assessee were also accepted. He, therefore, submitted that there was a reasonable cause in accepting the SBN which was deposited in the bank and the source of the same was duly explained and thus the addition made deserves to be deleted. 5. In reply, Id. Sr. DR submitted that the cash was received in SBN during the demonetization and the assessee being a trader in IMFL is not aut....

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....d income is estimated. The assessee is dealing in IMFL and had made retail sales of liquor wherein many cases customers took the goods and opened up the cap. Once the liquor bottle is opened, it cannot be returned to the seller as it cannot be accepted by any other customer and is a total loss to seller. Due to this compulsion and exceptional circumstances, the assessee had to accept the SBN in th....