DENTSPRO INDIA PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER, WARD-2(1)(3), BANGALORE

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ITA 1760/BANG/2025Status: DisposedITAT Bangalore11 June 2026AY 2019-204 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the addition made by the AO and the CIT(A). It found that the assessee failed to produce any documentary evidence to substantiate the cash sales or the opening cash balance, rendering the claim unsubstantiated.

What were the facts?

The assessee company made significant cash deposits during the demonetization period. The Assessing Officer (AO) made an addition of Rs. 47,07,500/- under Section 68 for these deposits, as the assessee failed to provide satisfactory evidence of their source, such as sales or opening cash balance.

What were the issues?

Whether the cash deposits made during demonetization are unexplained income under Section 68 of the Income Tax Act, 1961, due to lack of substantiating evidence.

Which sections of the Income-tax Act were involved?

Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH : BANGALORE

Before: SHRI BALAKRISHNAN S, ACCOUNTANT

For Respondent: Shri. Sreenivasa Karthik, ACIT(DR)(ITAT), Bengaluru
Hearing: 01.06.2026Pronounced: 11.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI BALAKRISHNAN S, ACCOUNTANT MEMBERAND SHRISOUNDARARAJAN K, JUDICIAL MEMBER ITA No.1760/Bang/2025 Assessment Year : 2019-20 M/s. Dentspro India Pvt. Ltd., Vs. ITO, No.3355/1, K. R. Road, Ward – 2(1)(3), Banashankari 2nd Stage, Bangalore- Bangalore. 560070, Karnataka. PAN : AAECD 2677 H APPELLANT RESPONDENT Assesseeby : None. Revenue by : Shri. Sreenivasa Karthik, ACIT(DR)(ITAT), Bengaluru. Date of hearing : 01.06.2026 Date of Pronouncement : 11.06.2026 O R D E R Per Balakrishnan S, Accountant Member : This appeal isfiled by the assessee against the order of learned Commissioner of Income Tax – Appeals (NFAC, Delhi) [in short “CIT(A)”] vide DIN No.ITBA/NFAC/S/250/2025-26/1078153514(1) dated 03.07.2025, for the Assessment Year 2017-18, arising out of the order passed under section 143(3) of the Act dated 28.12.2019.

2.

Brief facts of the case are assesseebeing a private limited company filed its return of income on 28.10.2017 declaring a total income of Rs.62,41,000/-. Subsequently, the case was selected for scrutiny under CASS and statutory notice under section 143(2) of the Act was issued on 24.09.2018. Subsequently,

ITA No.1760/Bang/2025 Page 2 of 4

notice under section 142(1) of the Act along with the detailed questionnaire was issued and served on various dates. The learned Assessing Officer [in short „AO‟], after perusing the details furnished by the assessee, noticed that as assessee has made cash deposits during the demonetization period amounting to Rs.3 lakhs in Corporation Bank, Rs.44,07,500/- in ICICI bank on various dates from 09.11.2016 to 31.12.2016. Being not satisfied with the reply furnished by the assessee regarding cash deposits which was claimed to be arising out of sales and the balance of cash available on 08.11.2016, the learned AO proceeded to make an addition under section 68 of the Act amounting to Rs.47,07,500/-.

3.

On being aggrieved by the addition made by the learned AO, the assessee filed appeal before the learned CIT(A). Similar submissions were made before the learned CIT(A). The learned CIT(A) did not consider the submissions of the assessee and dismissed the appeal of the assessee.

4.

On being aggrieved by the order of the learned CIT(A), assessee is in appeal before us by raising the following grounds:

ITA No.1760/Bang/2025 Page 3 of 4

5.

None appeared on behalf of the assessee however the written synopsis are available on record.

6.

The learned Departmental Representative [in short „DR‟] placed heavy reliance on the orders of the Revenue authorities.

We have perused the written synopsis of the assessee and heard the learned DR. The case of the learned AO is the assessee has made multiple cash deposits in the ICICI bank and Corporation bank accounts aggregating to Rs.47,07,500/- which was allegedly claimed by the assessee as arising out of the sales and also on the opening balance of cash available with various branches of the assessee. However, we find from the Order of the learned AO that no documentary evidences were produced before the learned AO substantiating the sales made by the assessee and also on the cash book declaring the opening balance as on 08.11.2016. Since the claim made by the assessee is without any cogent evidences, the learned AO disbelieved the submissions made by the assessee while making the additions. It was also found that cash sales during the demonetization period is only Rs.2,10,946/-. The assessee has neither furnished cash flow statements, cash books, VAT returns, invoice for cash sales and confirmation from field employees before the Revenue authorities or even before us. In these circumstances, we find that the learned CIT(A) has rightly adjudicated the case by upholding the order of the learned AO and we therefore

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find no infirmity in the order of the learned CIT(A). Thus the grounds raised by the assessee have no merits and hence dismissed.

7.

In the result, appeal of the assessee is dismissed.

Pronounced in the open court on the date mentioned on the caption page.

/Sd/- Sd/- Sd/- (SOUNDARARAJAN K) (BALAKRISHNAN S) Accountant Member Judicial Member Bangalore. Dated:11.06.2026. /NS/*

Copy to: 1. Appellants 2. Respondent 3. CIT 4. CIT(A) 5. DR 6. Guard file By order

Assistant Registrar, ITAT, Bangalore.

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