TaxTMI 
TaxTMI 
2026 (3) TMI 1491
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....sessee filed return of income declaring income of Rs. 5,16,960/-. The case of the Assessee was selected for complete scrutiny. An assessment order came to be passed u/s 143(3) of the Act on 19/02/2019 by making an addition of Rs. 37,75,000/- on account of cash deposited during the demonization period, made addition of Rs. 44,44,846/- due to mis-match in the custom duty paid by the Assessee and also made disallowance of Rs. 5,531/- and Rs. 32,077/- claimed by the Assessee as expenses. Aggrieved by the assessment order dated 19/12/2019, Assessee preferred Appeal before the Ld. CIT(A). The Ld. CIT(A) vide order dated 23/06/2025 confirmed the addition of Rs. 37,75,000/-. As against the order of the Ld. CIT(A) dated 23/06/2025, Assessee preferre....
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....ard both the parties and perused the material available on record. The Ld. A.O. while making the addition of Rs. 37,75,500/-, observed that no documentary evidence was produced in support of cash sale claimed by the Assessee and the same pattern does not match with the earlier sale and as the Assessee failed to justify the purpose of keeping cash in hand received from sale, accordingly, A.O. made the addition in the hands of the Assessee. The said addition made by the A.O. has been confirmed by the Ld. CIT(A) in following manners:- "The grounds of appeal no.4 to 12 relate to the sole issue of addition of Rs 37,75,000/- as unexplained cash credit and hence the same are consolidated and adjudicated together. 6.1 Various cont....
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....;s name and address, description of items sold with quantity, rate and value, coples of delivery of goods like transport receipt /delivery challanto show delivery of these from the place of appellant's business to the place of purchaser and finally the amount of cash receipt with date. It was also required on the part of appellant to provide details of corresponding purchase of goods with copies of purchase invoice and transport receipt / delivery challan. The appellant was also required to provide copies of purchase register, sales register, stock register etc. All these documentary evidences in support of cash sale are very much essential in the case of appellant especially considering that there was no cash sale during the entire ear....
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.... iv. VAT Returns for all four quarters- Q1, Q2, Q3,Q-4 reflecting Annual sales of Rs. 3,68,94,894/-, and which were never revised. v. Q-3 returns include cash sales of Rs. 3657935/- (plus Tax of Rs. 318083.25/- making Gross sales for Rs. 3976018.25) vi. Audited Balance sheet reflecting sales values of Rs. 3,68,94,894/-, which is tallying with consolidated sales of all quarters DVAT Return vii. Supporting records evidencing source of cash deposits 8. It is a matter of record that, at no point of time, A.O. rejected the books of accounts of the Assessee and no defects or adverse inference was drawn and confronted to the Assessee. The addition has been made by the A.O. disregarding the VAT Returns and Sales Tax ....