TaxTMI 
TaxTMI 
2025 (4) TMI 2228
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....inst the assessment order u/s 143(3) of the Act, dated 24.12.2019. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. For that the learned A.O. is not justified in making addition of Rs. 16,28,000/- u/s 69A of I.T. Act on account of cash deposited during demonetization period. 2. The Appellant craves the leave to take Additional Grounds at the time of hearing of appeal." 3. Brief facts of the case are that the assessee filed the returns of income on 16.03.2018 for AYs 2016-17 and 2017-18 and both the returns were selected for scrutiny through CASS. It is stated in the Statement of Facts filed before the Ld. CIT(A) that relevant papers were submitted in support of the returns....
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..... 41,42,250/- as per the reply filed before the Ld. AO. The main source of depositing the cash into the cash credit account was out of collection from trade receivable goods sold on credit during the financial period 2013-14 to 2015-16 and it was submitted that the same can be cross checked with the audited account already uploaded in the income tax portal during the period 2014-15. A copy of ledger account of Royal Electronics in the books of Computer Vision Works where some transactions had been shown for the FY 2015-16, a rough trading and profit and loss account for the FYs 2014-15 and 2015-16 and some purchase voucher and sale vouchers issued during the FY 2016-17 were also filed before the Ld. AO along with the above reply. The Ld. AO....
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.... maintained proper books of account for the year and had declared income under the head "other sources" and had also deposited Rs. 16,28,000/- in the bank account during the demonetization period. In the appellate proceedings the assessee wished to explain these as his business receipts. Since there were several contradictions in the explanation given as pointed out by the Ld. AO and the assessee had not been able to resolve these in the appellate proceeding, therefore, the addition of Rs. 16,28,000/- made u/s 69A of the Act was confirmed and the appeal was dismissed. Aggrieved with the order of the Ld. CIT(A) the assessee has filed the appeal before this Tribunal. 5. Rival submissions were heard and the paper book filed was examined. It....
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....realized from business receivables as shown in the ITR for the AY 2014-15. Our attention was also drawn to para 2.0 and 3.0 on page 7 of the paper book being the assessment order relating to the AY 2016-17 in which these transactions are mentioned and the fact of audited balance sheet is also mentioned at para 3.0 of the assessment order. It was submitted that for the AY 2017-18 the facts were similar and as per pages 1 to 5 of the paper book similar explanation was submitted and the Ld. AO did not find any fault for AY 2016-17 but refused to accept the deposits made during the period relevant for AY 2017-18. It was submitted that minor purchases and sales were also made for the customers of the business and the Ld. AR on behalf of the asse....
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....should be answered in the affirmative, namely, that the Tribunal was justified in holding that the income derived by the Radhasoami Satsang was entitled to exemption under sections 11 and 12." 6. The Ld. AR requested that as the business receipts were accepted for AY 2016-17 during the scrutiny proceeding, the same explanation ought to have been accepted for AY 2017-18 as well as the assessee had given detailed reply of comparative cash sales and cash deposits during the two financial years in the course of the assessment proceedings and in the appeal before the Ld. CIT(A) for AY 2017-18. 7. We have considered the submissions made and have also gone through the facts of the case. The Ld. AO accepted the returned income of the assessee....