AI Drafter 
TaxTMI 
TaxTMI 
2026 (3) TMI 1705
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.... raised 16 grounds, which we for the sake of brevity and convenience are not inclined to reproduce here. 3. The grounds of appeal are interconnected and relate to the addition made by the AO under section 69A of the Act amounting to Rs. 16,16,400 treating the cash deposits made during the demonetisation period as unexplained. 4. During assessment proceedings, the assessee before AO submitted that no cash has been deposited in the bank account during the period under consideration. However, the AO found that the assessee did not furnish copies of the bank statements for verification of the assessee's claim. The AO observed that the assessee failed to substantiate that the cash deposits made during the demonetisation period were out of ....
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....d. CIT-A, the assessee preferred an appeal before us. 8. The Ld. AR before us has submitted a paper book running from pages from 1 to 50, containing the written submissions, bank certificate, ledger extract of customer, sales ledger, ITR & Financials and order of lower authorities. 8.1 The Ld. AR submitted that the assessee has been carrying on regular business transactions with the customer, Shri Kanhiyalal Jesaram of Ajmer, Rajasthan. It was contended that the impugned cash deposit in the Axis Bank account was made by the said customer towards sale proceeds arising from genuine business transactions with the assessee. The Ld. AR further submitted that the said amount has been duly recorded in the regular books of account of the asse....
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....dwin Tourism Pvt. Ltd. v. DCIT in [IT Appeal No. 2786 (Del) of 2019, dated 21-8-2024] (e) Income-tax Officer vs. J.K. Wood India (P.) Ltd. reported in [2024] 158 taxmann.com 208 (Delhi - Trib.)/[2024] 205 ITD 10 (Delhi - Trib.)[03-01-2024] (f) JCIT Vs. M/s Pari Agencies Pvt. Ltd. in ITA No. 2006/Del/2023 dated 14.12.2023 (g) Mohit Sukhija vs. NFA reported in [2025] 175 taxmann.com 94 (Delhi - Trib.)/[2025] 213 ITD 251 (Delhi - Trib.)[30-05-2025] (h) DSA Motors vs. Income-tax Officer reported in [2025] 175 taxmann.com 161 (Chennai - Trib.)[26-05-2025] 9. On the contrary, the Ld. DR vehemently supported the orders of the AO and the Ld. CIT(A). It was submitted that the assessee failed to substantiate the....
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....nion of the AO, then the money and the value of the bullion, jewellery or other valuable article may be deemed to be the income of the assessee of such financial year. 10.1 As per plain reading following condition must be fulfilled for applicability of section 69A of the Act: 1. Assessee is found to be owner of any money, Bullion, Jewellery etc. 2. Such Money is not recorded in the books of accounts, if any maintained by him for any source of income, AND 3. Assessee offers no explanation or explanation is found not satisfactory by AO. 10.2 In the present case, we note that the cash deposits in question are duly reflected in the bank account of the assessee and the assessee has also placed on record the ledge....
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....on the Judgment of ITAT Visakhapatnam in the case of Assistant Commissioner of Income Tax v. Hirapanna Jewellers [2021] 128 taxmann.com 29/189 ITD 608 (Visakhapatnam - Trib.)/2021 (5) TMI 447, dated: 12-5-2021 held as under:- "9. In view of the foregoing discussion and taking into consideration of all the facts and the circumstances of the case, we have no hesitation to hold that the cash receipts represent the sales which the assessee has rightly offered for taxation. We have gone through the trading account and find that there was sufficient stock to the sales and we do not find any defect in ccoun effect the stock as well as the sales. Since, the assessee has already admitted the sales as revenue receipt, there is no case for ma....