2025 (3) TMI 1671

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....ct on 31-12-2019. Having heard vehement arguments of both the sides and upon perusal of case records, the appeal is disposed-off as under. During the year, the assessee being resident corporate assessee is stated to be engaged in trading of jewellery. Assessment Proceedings 2. During assessment proceedings, the assessee was required to explain the source of cash deposited by it during demonetization period. The assessee furnished various documents and replies. It was observed by Ld. AO that the assessee deposited huge cash of Rs. 757.87 Lacs on a single day which was not commensurate with the past trends. The sales also revealed abnormal trend in comparison to earlier year. The Ld. AO, drawing various statistical inferences, alleged t....

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.... and sales bills were produced and the valuation of stock was accepted. The books were not rejected u/s 145(3). The cash sales as allegedly termed as bogus sales already stood included in total sales and profit arising there-from stood included in the profits already disclosed by the assessee in the return of income. The entire sales on 08-11-2016 was out of stock-in-hand. The opening stock as on 01-04-2016 was Rs. 17.23 Crores and Ld. AO could not establish that alleged cash sales were made out of books or out of stock which was not available with the assessee. The assessee submitted plethora of documents to support its claim. The sales in October, 2016 were more due to festival season. The abnormal sales on 08-11-2016 were due to announce....

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....me. The assessee has duly furnished stock register as well as cash book which would show that corresponding entry of purchase and sales was made therein and the same were duly recorded in the books of accounts. The assessee had sufficient closing cash-in-hand as on 08-11-2016 to make impugned deposits in the bank accounts. The sales are supported by sales invoices. The sales made by the assessee were duly credited in the Profit & Loss Account and sales were duly reflected in the VAT returns. A separate addition thereof without reducing purchases would amount to double taxation which is impermissible. 5. It could also be seen that the assessee has furnished plethora of documents in support of its submissions. The same include Tax Audit Re....