2026 (2) TMI 1126

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....tra (Advocate) - Ld. ARs For the Respondent : Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl.CIT) - Ld. DRs ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2017- 18 arises out of an order of Ld. Commissioner of Income Tax (Appeals)-3, Gurgaon [CIT(A)] dated 26-08-2025 in the matter of an assessment framed by Ld. AO u/s 143(3)....

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....e was subjected to survey on 28-02-2017 and the assessee offered disclosure of Rs. 75 Lacs under Prime Minister Garib Kalyan Yojna and paid due taxes. The assessee stated that the cash was deposited out of cash-in-hand as available in the regular books of accounts. The cash was generated out of sale proceeds of jewellery stock. The assessee furnished books of accounts during the course of assessme....

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..... 737.57 Lacs which worked out to be Rs. 221.27 Lacs. After giving credit of disclosure of Rs. 75 Lacs, the remaining amount of Rs. 146.27 Lacs was added to the income of the assessee as unexplained cash deposit u/s 68 r.w.s. 115BBE of the Act. Upon further appeal, Ld. CIT(A) reduced the disallowance to the extent of 20%. Aggrieved, the assessee is in further appeal before us. 4. It clearly eme....

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....hout any well founded logic and reasoning. The Ld. AO has merely stated that the bills did not bear proper name and address of the customers. However, there is no material to hold that these sales were not genuine. The cash sales have duly been offered to tax by way of credit in Profit & Loss Account. Making separate addition thereof would be nothing but double taxation which is impermissible. The....