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2026 (3) TMI 315

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....essee and Shri Sandeep Kumar Mehta, Sr. DR represented on behalf of the revenue. 3. It was submitted by the ld. AR that assessee is in the business of clothing, apparels, dying and retail sale. It is the submission that during the demonetization period the assessee had deposited Rs. 1,43,54,500/-, this consisted of demonetized currency. It was the submission that the ld. AO assumed the figure to be Rs. 3,45,00,450/- on the basis of ITS details available with the ld. AO. However, at the time of making the addition, the ld. AO made an addition of Rs. 1,48,53,500/-. It was the submission that the ld. CIT(A) enhanced the addition to Rs. 3,45,00,450/- on the ground that the ld. AO had determined the figure as per ITS details at Rs. 3,45,00,45....

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....t of Rs. 3,45,00,450/- was the figure shown in the ITS portal. It was the submission that there could have been duplication and the AO might have taken the corrected figure at Rs. 1,48,53,500/-. It was the submission that this could be verified if at all. It was the further submission by the ld. Sr. DR drew our attention to page no. 294 of the Paper Book, which read as follows:- It was the submission that this was the ledger account of the assessee in respect of sales and this clearly showed that it could be manipulation of the accounts. It was the submission that the addition was made by the AO is liable to be upheld. It was the further submission that in regard to enhancement as done by the ld. CIT(A), he had no objection if the issue ....

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....to technical reasons in respect of notice was issued u/s 143(2) of the Act, the same are not being adjudicated as the addition itself has been deleted on merits. 7. In the result, the appeal of the assessee stands allowed. Order pronounced in the open court on 27.01.2026. ============= Document 1 35 NEW SAHA DYERS AND PROCESSORS 230/.235/20 MIRPARA ROAD LILUAH, HOWRAH-711204 Date Note PSS Amount Total Amount 11-11-201'6 192 1000 500 473 4036 473000 2018000 2491000.00 13-11-2016 187 1000 1370 3732 1370000 3236000.00 500 1866000 17.112016 142 1000 500 2549 6902 2549000 3451000 6000000.00 18.11.2016 500 2000 1000000.00 25.11.2016 692 1000 267 257000 500 304 152000 415000.00 01.12.2016 ....

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....sh 9-Nov-2016 Book to 31-Dec-2016 Page 1 Date Particulars Vch Type Vch No. Debit Credit 9-11-2016 To Opening Balance 1,48,38,500.00 11-11-2016 By Bank of India Cash Credit A/c No-403130110000071 Contra 72 24,91,000 00 Amount deposited in to bank 13-11-2016 By Bank of India Cash Credit A/c No-403130110000071 Contra 73 32,36,000.00 Amount deposited in to bank. 15-11-2016 By WAGES Payment 301 85,500.00 Amount paid by cash for 15 days of wages 17-11-2016 By Bank of India Cash Credit A/c No-403130110000071 Contra 74 60,00,000.00 Amount deposited m to bank 18-11-2016 By Bank of India Cash Credit A/c No-403130110000071 Contra 75 10,00,000.00 Amount deposited in to bank 21-11-2016....

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....OCESSORS sh Book : 9-Nov-2016 to 31-Dec 2016 Page 2 Date Particulars Vch Type Veh No Debit Credit Brought Forward 14,52,600.00 8,50,000.00 2-12-2016 To Sales (Hosiery Than ) Amount meived by cash. Sales 4063 10,500.00 5-12-2016 By Bank of India Cash Credit A/c No-403130110000071 Contra 78 2,67,000 00 Amount deposited in to bank 10-12-2016 To Sales (Hosiery Than ) Sales 4071 11,250.00 Amount reeived by cash. 12-12-2016 By Factory Expenses Payment 334 4,150.00 Amount paid by cash. 15-12-2016 By Bank of India Cash Credit A/c No-403130110000071 Contra 79 8,000.00 Amount deposited in to bank By WAGES Payment 33 85,500.00 Amount paid by cash for 15 days of wages. 19-12-2016 By Bachhu ....