TaxTMI 
TaxTMI 
2026 (7) TMI 551
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.... assessee is that the assessee is in the business of trading in readymade garments. The assessee has a shop at Berla, Chhattisgarh and he does retail business regarding purchase and sale of readymade garments. The total cash deposits made by the assessee in the bank account for the year was to the tune of Rs. 56,38,000/- out of which the A.O. added Rs. 20.17 lakhs under section 69A of the Act as unexplained money of the assessee on the ground that those were SBN notes and they were deposited during the demonitisation period. 3. At the level of CIT(A) the relief was given to the assessee to the tune of Rs. 2,23,000/- and the remaining amount addition of Rs. 17.93 lakhs were sustained. The Ld. Counsel further submitted that they had provid....
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....sessee. But in this case the assessee has explained the entire nature and source of cash deposits to the Department. The assessee had furnished month-wise cash flow statement pertaining to the readymade sales made, the assessee had also furnished the list of sundry debtors and also had submitted that about 15 lakhs he had withdrawn from his account and had redeposited the same in his bank account. 6. On the other hand, the Department had just rested on these submissions of the assessee without verifying or without examining the veracity and genuineness. In spite of having entire machinery with the Department neither the A.O. nor the CIT(A) had verified the contentions of the assessee and had summarily dismissed all these documents submit....
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....ns from the debtors regarding the repayment of the loans and payment to the assessee. Thirdly, regarding the agricultural income the land belonged in the name of the daughter of the assessee, therefore, the amount from agriculture was questionable by the Department. 3. In rebuttal to the argument of the Sr. DR the Ld. Counsel for the assessee brought to the notice of the Bench at Page 31 & 32 of the Paper Book the list of the debtors from whom the money was received and the entire details were submitted before the Department. Secondly, even at Page 33 of the Paper Book the month-wise sale details and cash receipts from debtors have been placed before the Department. The Sr. DR contented that these were never submitted before the A.O. How....
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....ransaction even without confirmation in relation to the type of business activity of the assessee, therefore, cannot be disputed and more so for the reason that the Revenue has also not brought on record any evidence to suggest otherwise. The fact of the matter is when the Department has accepted the source of income of the assessee, when the entire nature of source of cash deposits had been explained and when the Revenue Authorities have not conducted independent enquiry, in such scenario it is also not open for the Revenue Authorities to summarily make additions in the hands of the assessee under section 69A of the Act as unexplained money regarding the cash deposits made since the nature and source has already been explained by the asses....