M/S A P JEWELLERS,AGRA vs. DCIT, CIRCLE 2(1)(1), AGRA, AGRA

ITA 353/AGR/2026Status: DisposedITAT Agra07 August 2026AY 2017-189 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the cash sales were duly recorded in the audited books of accounts, supported by sales invoices and stock registers. The jurisdictional High Court's decision on similar facts was followed, stating that the revenue cannot substitute actual sales with estimated figures without adverse material.

What were the facts?

The assessee, a jeweller, deposited Rs. 2,40,29,635/- in cash during the demonetization period, claiming it as cash sales. The Assessing Officer treated this as unexplained cash credit and added it to the total income. The CIT(A) upheld this addition.

What were the issues?

Whether cash deposits during demonetization, claimed as sales, can be treated as unexplained cash credit when supported by audited books of accounts and sales invoices. Whether Section 115BBE is applicable for AY 2017-18.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE,Section 143(1),Section 142(1),Section 145(3),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA (DB

Before: SUNIL KUMAR SINGHBRAJESH KUMAR SINGH

For Appellant: Shri. Anil Verma, Adv & Shri Dheeraj
For Respondent: Shri Anil Kumar, Sr (DR)
Hearing: 24.06.2026Pronounced: 07.08.2026

PER:SUNIL KUMAR SINGH, JUDICIAL MEMBER

This appeal is directed against the impugned order dated 11.03.2026 passed in appeal No CIT(Appeal) 2, Agra/10719/2019-20 by the ld. Commissioner of Income Tax/ NFAC(Delhi) (hereinafter referred to as the “CIT(A) u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2017-18, wherein ld CIT(A) has dismissed assessee’s appeal.

2.

The brief facts state that appellant assessee firm was engaged in the business of trading and manufacturing of gold and silver ornaments and follows mercantile system of accounting. The assessee e-filed its return of income on 28.10.2017, declaring total income of Rs. 2,07,39,850/-.

The order continues below.

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