VRINDAVAN INTERNATIONAL TRADE PRIVATE LIMITED,. vs. ITO WARD-26(3), DELHI, .

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ITA 2425/DEL/2026Status: DisposedITAT Delhi29 June 2026AY 2017-183 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the assessee had not fully discharged its onus, the possibility of cash turnover in the business could not be ruled out. Therefore, a lumpsum addition of Rs. 4 lakhs was deemed just and proper.

What were the facts?

The assessee, engaged in clothes trading, had cash deposits of Rs. 44,92,000 during the demonetization period. The lower authorities assessed these deposits as unexplained under Section 68 of the Income Tax Act.

What were the issues?

Whether cash deposits during demonetization are unexplained income under Section 68, and the applicability of Section 115BBE to transactions prior to April 1, 2017.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

For Appellant: Adv. Sh. Dishant Sethi, Adv
Hearing: 01.06.2026Pronounced: 01.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.2425/Del/2026 Assessment Year: 2017-18 Vrindavan International Vs. Income Tax Officer, Trade Pvt. Ltd., Ward-26(3), C/o-IPSO, Legal H-35, 1st Delhi Floor, Jangpura Extension, New Delhi PAN: AAECV7845D (Appellant) (Respondent) Assessee by Sh. Rajiv Saxena, Adv. Sh. Dishant Sethi, Adv. Sh. Shyam Sundar, Adv. Department by Sh. Manoj Kumar, Sr. DR Date of hearing 01.06.2026 Date of pronouncement 01.06.2026 ORDER This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1086511725(1), dated 25.02.2026 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No.2425/Del/2026

2.

Coming to the assessee’s sole substantive ground raised herein, I notice that it seeks to reverse both the learned lower authorities’ respective findings assessing its cash deposits during demonetization period amounting to Rs.44,92,000/- as unexplained under section 68 of the Act; in assessment order dated 31.12.2019 as upheld in the lower appellate discussion. 3. I have given my thoughtful consideration to the assessee’s and the Revenue’s respective vehement submissions. I wish to make it clear that there has been no dispute all along that the assessee is engaged in the business of clothes trading etc. possibility of cash turnover in such an unorganized sector could not be altogether ruled out. And that it had all along filed all the relevant details of the business turnover during demonetization, whose credit could not be denied in entirety, although it appears to have not successfully discharged its onus of pleading and proving its explanation to the very effect. Be that as it may, I thus deem it appropriate in this factual backdrop that a lumpsum addition of Rs.4 lakhs in the assessee’s hands would be just and proper with a rider that the same shall not be treated as a precedent. The

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ITA No.2425/Del/2026

assessee gets relief of Rs.40,92,000/- in other words. Necessary computation shall follow as per law. 4. So far as assessee’s assessment under section 115BBE is concerned, I quote S.M.I.L.E. Microfinance Ltd. Vs. ACIT, W.P. (MD) No.2078 of 2020 & 1742 of 2020, dated 19.11.2024 (Madras) that the impugned statutory provision would come into effect on the transaction done on or after 01.04.2017 only. The assessee is accordingly directed to be assessed under the normal provision as per law. No other ground or argument has been pressed before us. 5. This assessee’s appeal is partly allowed. Order pronounced in the open court on 1st June, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 29th June, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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