VP COLD STORAGE & FARMS PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD-27(4), DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.8571/Del/2025 Assessment Year: 2017-18 M/s. VP Cold Storage & Vs. Income Tax Officer, Farms Pvt. Ltd., Ward-27(4), U-112, Lower Ground Floor, Delhi Main Vikas Marg, Shakarpur, Delhi PAN: AAACV5257H (Appellant) (Respondent) Assessee by Sh. Anurag Sinha, Adv. Department by Sh. Choudhary N.C. Roy, Sr. DR

Date of hearing 14.05.2026 Date of pronouncement 14.05.2026 ORDER PER SATBEER SINGH GODARA, JM 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/250/2025-26/1081957226(1), dated 23.10.2025 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

ITA No.8571/Del/2025

Heard both the parties. Case file perused. 2. Coming to the assessee’s sole substantive ground raised herein, we notice that it seeks to reverse both the learned lower authorities’ respective findings assessing its cash deposits during demonetization period amounting to Rs.1,38,20,000/- as unexplained under section 68 of the Act; in assessment order dated 31.12.2019 as upheld in the lower appellate discussion. 3. We have given our thoughtful consideration to the assessee’s and the Revenue’s respective vehement submissions. We wish to make it clear that there has been no dispute all along that the assessee is engaged in the business of cold storage wherein 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, we deem it appropriate in this factual backdrop that a lumpsum addition of Rs.8,20,000/- lakhs in the assessee’s hands would be just and proper with a rider that the same shall not be treated as a

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ITA No.8571/Del/2025

precedent. The assessee gets relief of Rs.1,30,20,000/- in other words. Necessary computation shall follow as per law. 4. So far as assessee’s assessment under section 115BBE is concerned, we 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 14th May, 2026 Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 2nd 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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