DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, VADDOARA, VADODARA vs. P MANEKLAL SONI AND CO., DAHOD

ITA 2375/AHD/2025Status: DisposedITAT Ahmedabad14 September 2026AY 2017-187 pages
AI SummaryDismissed

What were the facts?

The Assessing Officer made an addition of INR 1,23,56,000/- under Section 69A as unexplained money, attributing it to cash deposits during demonetization. The assessee claimed these deposits were from cash sales, supported by their cash book and sales ledger.

What did the Tribunal hold?

The Tribunal held that Section 69A cannot be invoked when cash deposits are duly recorded in the books of accounts and the income from sales has already been offered to tax. The Assessing Officer had not rejected the books of accounts or disputed the sales, purchases, or stock position.

What were the issues?

Whether cash deposits, which are explained as cash sales recorded in the books of account and offered to tax, can be treated as unexplained money under Section 69A. Whether Section 69A is applicable when the books of account are not rejected and sales are not disputed.

Which sections of the Income-tax Act were involved?

Section 69A,Section 143(3),Section 133(6),Section 145(3),Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, B” BENCH, AHMEDABAD

Per Rahul Chaudhary, Judicial Member:

1.

The present appeal has been preferred by the Revenue against the Order, dated 23/09/2025, passed by the Commissioner Of Income Tax, (Appeals)-12 Ahmedabad [hereinafter referred to as the ‘CIT(A)’] whereby the Learned CIT(A) had partly allowed the appeal against the Assessment Order, dated 16/12/2019, passed under Section 143(3)of the Income Act, 1961 [hereinafter referred to as ‘the Act’] for the Assessment Year 2017-2018. 2. The Revenue has raised following grounds of appeal:

1.

On the facts and in the circumstances of the case and in law, the Ld.

The order continues below.

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