MILAP GKG RIPENING CHAMBERS,AMBALA vs. ITO WARD-4, AMBALA, AMBALA

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI LALIET KUMAR,JM AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.1085/CHANDI/2025 (िनधा�रण वष� / Assessment Year: 2017-18) M/s Milap GKG Ripening Chambers ITO Ward – 4 Plot No. 418, HSIDC, Saha Ambala बनाम/ Vs. Ambala City, Ambala Haryana - 133001 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AAWFM-7929-A (अपीलाथ�/Appellant) (��थ� / Respondent) : अपीलाथ�कीओरसे/ Appellant by : Sh. Ajay Jain (CA) – Ld. AR ��थ�कीओरसे/Respondent by : Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 05-05-2026 घोषणाकीतारीख /Date of Pronouncement : 11-05-2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2017-18 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A) dated 06.08.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 147 r.w.s. 144B of the Act on 29.03.2022. The sole issue that arises for our consideration is addition of cash deposits for Rs.20 Lacs. Having heard

rival submissions and upon perusal of case records, the appeal is disposed-off as under. 2. The assessee being resident firm was found deposited cash of Rs.62.77 Lacs during the year. To examine the same, the case was reopened and notice u/s 148 was issued on 30-03-2021. The specified bank notes (SBN) as deposited by the assessee was Rs.21.80 Lacs. The deposits were stated to be made out of cash sale of bananas to small vendors. In support, the assessee filed few confirmations. However, the same stood rejected by Ld. AO on the ground that the copy of income tax return was not furnished by the assessee. Accordingly, presuming cash balance of Rs.1.80 Lacs on 08-11-2016, the remaining amount of Rs.20 Lacs was added to the income of the assessee u/s 68. The Ld. CIT(A) upheld the addition against which the assessee is in further appeal before us. 3. Upon perusal of documents as placed on record, it could be observed that the assessee has declared turnover of more than Rs.856.96 Lacs and its books of account are duly audited. The assessee’s business model is such that substantial sales are made in cash which is evident from the fact that the assessee has made cash deposits of Rs.504.91 Lacs during whole year. The deposits before demonetization period are for Rs.364.66 Lacs whereas cash deposits during demonetarization period are for Rs.57.42 Lacs. The cash sales in the year are Rs.133.86 Lacs. Similar is the pattern in earlier year. The cash summary would indicate that the assessee is having sufficient cash balance as on 08-11-2016 to make impugned deposits.

The deposits are out of sale proceeds which had duly been reflected in the VAT returns and the sales turnover has been accepted by Ld. AO. No defect has been pointed out in the books of the assessee. On these facts, the source of Rs.20 Lacs could not be doubted. Therefore, we delete the impugned addition on merits. No other ground has been urged in the appeal. 4. The appeal stand allowed. Order pronounced on 11th May, 2026.

-Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 11-05-2026 AS 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

ASSISTANT REGISTRAR

ITAT CHANDIGARH