NEERAJ GOYAL,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, DCIT CIRCLE, PANCHKULA

आदेश / O R D E R RAJESH DAMODARLAL SHARMA (Judicial Member) 1. This appeal filed by the assessee for Assessment Year (AY) 2017- 18 is directed against the order passed by Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 18.12.2025 in the matter of an assessment framed by Ld. AO u/s 143(3) on 03.12.2019. Having heard rival submissions, the appeal is disposed-off as under.

ITA No. 345/Chd/2026 AY : 2017-18 Neeraj Goyal 2. The assessee is stated to be engaged in civil contract work under his proprietory concern M/s Bharat Construction Company. It transpired that the assessee made cash deposits of Rs.10.95 Lacs in its bank accounts which were stated by the assessee to be deposited out of earlier withdrawals. The Ld. AO rejected the explanation of the assessee and added the same as unexplained cash deposits. The Ld. CIT(A) confirmed the addition against which the assessee is in further appeal before us. 3. The Ld. AR stated that the assessee is a government contractor executing works across multiple site locations in Haryana. Due to the very nature of the construction business, the assessee is required to maintain cash-in-hand for day-to-day operational expenses at various project sites. The Ld. AR explained that during the relevant financial year, the assessee withdrew cash from his bank accounts for business operational requirements. Out of the available cash-in-hand, impugned deposits were made during demonetization period. It has further been submitted that the cash-in-hand also include unutilized imprest cash returned by employees at different sites. All these cash transactions are stated to be fully accounted for and the same form part of assessee’s cash book as maintained in the regular course of business. To support the same, Ld. AR referred to Pages 141 to 147 (Cash Book), Pages 30 to 138 (Bank Statements), and Pages 139 to 140 (detailed source chart of cash deposits) of the paper book to demonstrate the complete trail of cash withdrawals, cash availability, and subsequent deposits etc. It has vehemently been contended that

ITA No. 345/Chd/2026 AY : 2017-18 Neeraj Goyal Ld. AO made the addition purely on suspicion, conjectures and surmises and without rejecting the audited books of account or pointing out any specific defect in the contemporaneous records as submitted by the assessee. The Ld. Sr. DR referred to the findings of lower authorities. 4. From enumerated facts, it is quite clear that the assessee work as civil contractor which require cash payments at various project sites. For this, the assessee maintains requisite cash-in-hand for operational site expenses which is a routine commercial necessity. We find that assessee’s books of accounts are duly audited. The books are not rejected and no defect has been pointed out by Ld. AO in the same. Upon examination of cash book (Pages 141 to 147), bank statements (Pages 30 to 138), and the summary chart depicting the source of cash deposits (Pages 139 to 140), we find that there was sufficient cash balance available in the cash book on the respective dates of deposits. The cash re-deposited into the bank accounts is clearly traceable to prior bank withdrawals and returned site imprest balances. This being so, the deposits stand fully explained and there remain no reason to treat the same as unexplained deposits. Therefore, we delete the impugned addition and allow the corresponding grounds of appeal. 5. The assessee has also assailed addition of Rs.14,059/- which represent difference in gross business advances pertaining to M/s ASCO Corporation, Sonipat. No plausible explanation has been furnished before us with respect to the same. Therefore, this addition do not call for any interference on our part.

ITA No. 345/Chd/2026 AY : 2017-18 Neeraj Goyal 6. The appeal stand partly allowed. Order pronounced on 01-09-2026

-Sd- -Sd- (MANOJ KUMAR AGGARWAL) (RAJESH DAMODARLAL SHARMA) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 01-09-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

BY ORDER ASSISTANT REGISTRAR INCOME TAX APPELLATE TRIBUNAL KENDRIYA SADAN, SECTOR – 9A CHANDIGARH