2023 (10) TMI 1595

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....n of Rs. 3,84,35,000/- on account of cash deposited during the demonetization period by accepting the additional evidence under rule 46A of the I. T. Rules, 1962 submitted by the assessee ignoring the fact that the assessee deliberately failed to submit the evidence during the assessment proceedings and it was not prevented by any sufficient cause to submit the same during the assessment proceedings. 2. The Ld. CIT(A) has erred in deleting the addition of cash deposited during the demonetization period ignoring the fact that the cash deposited out of cash sale for the month of November, 2016 was significantly higher which is around more than double to the cash sale during the same month. 3. The Ld. CIT(A) has erred in dele....

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....,20,000/-. The AO further made addition on account of difference in stocks amounting to Rs. 2,17,05,339/- and also made addition of Rs. 1,15,038/- in respect of gross profit. Further, the AO made addition of Rs.2 crore being the amount admitted by the Director of the company. Further, the AO made addition on account of unsecured loan amounting to Rs. 15 lakh and on account of unverifiable expenses amounting to Rs. 8,37,128/-. Hence, the AO assessed income at Rs. 10,75,43,059/-. The only effective ground in this appeal is against deleting the addition of Rs. 3,84,35,000/- on account of cash deposited during the demonetization period. 3. The ld. DR supported the assessment order and submitted that the ld. CIT(A) was not justified in deleti....

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.... which are being sold in cash regularly. (ii) The appellant is depositing all these cash sales in its regular bank accounts only as is evident from the above tables. In some years, the cash deposits are more than the cash sales, which may be due to opening cash in hand and other cash receipts. (iii) Month wise cash sales of the appellant for various months for FYs 2015-16 to FY 2017-18 do not show any abnormal trend. (iv) % of cash sales to total sales for the month of October and November also do not show any abnormality. In fact, October 2015 figure is much higher than the corresponding figure for 2016. Had there been any backdating to increase the cash sales for October and November 2016(up to 8th), it would ha....