2025 (3) TMI 1932

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.... CA & Shri Ashu Garg, CA ORDER PER AMITABH SHUKLA, AM: This appeal by Revenue is directed against the order of National Faceless Appeal Centre, Delhi [for short hereinafter referred to as the "(Ld. CIT(A)"] dated 04.03.2024 for Assessment Year 2017-18. 2. The only issue in this appeal of Revenue is regarding the action of Ld. CIT(A) and deleting the addition of Rs. 1,63,57,462/- made b....

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....16-17, so as to allude towards huge variation in cash sales. The Ld. AO noted that the cash sales before commencement of demonetization was significantly high raising doubts towards its justified sources. The Ld. Counsel submitted that as evident from para 8 to 8.3 of his order on pages 23 to 26 of the Ld. AO, conclusions were drawn qua lack of genuineness of the cash sales made from 01.10.2016 to....

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.... in its bank account. The order of the Ld. AO is totally silent as to whether any doubt was raised qua genuineness of the sales. Now once, the genuineness of the sales has been accepted, the cash generated from such sales cannot be a subject matter of any inquiry or addition. In case, the AO doubted the genuineness of the sales, then he ought to have re-casted the entire trading results. The asses....