2025 (3) TMI 1670

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....n 30-09-2021. 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 individual carried out business activities in proprietorship concern namely M/s Parshant Silver Handicrafts. Assessment Proceedings 2.1 The assessee's return of income was initially processed u/s 143(1). However, pursuant to search action on in the case of R.S. Bullion and Jewellers Group of cases at Mathura on 19-07-2018 which included the assessee, notice u/s 153A was issued to the assessee on 24-09-2020. 2.2 During the course of assessment proceedings, it was noted by Ld. AO that the assessee deposited cash in the form of Specified Bank Notes (SBNs) du....

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....Ld. CIT(A) proceeded to adjudicate the issue on merits after careful consideration of Ld. AO's findings as well as in the light of elaborate written submissions as made by the assessee. The adjudication of Ld. CIT(A) is contained at paras 8.4 onwards of the impugned order. 3.2 The Ld. CIT(A) observed that the assessee was a dealer in silver and gold bullion and it was duly registered under VAT laws. The assessee was regular Income Tax Assessee and it maintained regular books of accounts including stock records. The books were duly audited u/s 44AB. The sales made by the assessee were subjected to VAT. The cash was deposited in regular bank accounts and duly disclosed in the return of income as filed by the assessee on 22-07-2017 i.e., mu....

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.... the assessee are subjected to VAT and the sales are duly reflected in the VAT returns. Apparently, no fault has been found in the sales made by the assessee. Considering the volume of business, the assessee is required to maintain proper books of accounts as well as quantitative details of stock etc. which, in fact, has been done by the assessee. These books of accounts have duly been audited under law and the same were furnished to Ld. AO during the course of assessment proceedings. The books have not been rejected and no single effect has been pointed out in the same. 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 ....