PARASMANI JWELLERS,AHMEDABAD vs. ITO, WARD 5(3)(2), AHMEDABAD, AHMEDABAD

ITA 1841/AHD/2026Status: DisposedITAT Ahmedabad12 October 2026AY 2017-184 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the approach of the Assessing Officer and the CIT(A) in brushing aside the documents furnished by the assessee without pointing out any defect or discrepancy was not sustainable. The Tribunal found that the cash sales, cash receipts, and cash deposits were all recorded in the assessee's books of account, and the AO had neither rejected the books of account nor disturbed the sales. Therefore, the provisions of Section 69A of the Act were not attracted. The Tribunal relied on the judgment of the Hon'ble High Court of Gujarat in PCIT v. Jewel World. Consequently, the addition of INR 50,00,000 made under Section 69A was deleted. Grounds 1 and 2 raised by the assessee were allowed.

What were the facts?

The assessee, Parasmani Jewellers, filed its return of income for Assessment Year 2017-2018 declaring a total income of INR 6,56,870. The case was reopened under Section 147 of the Income Tax Act, 1961, based on information regarding cash deposits of INR 50,00,000 during the demonetization period. The Assessing Officer (AO), under Section 147 read with Section 144B, rejected the assessee's objections, added INR 50,00,000 under Section 69A as unexplained money, and assessed the total income at INR 56,56,870. The National Faceless Appeal Centre (NFAC), Delhi, upheld the reopening and the addition. The assessee appealed to the Income Tax Appellate Tribunal (ITAT).

What were the issues?

1. Whether the addition of INR 50,00,000 made under Section 69A of the Act in respect of cash deposits and taxed under Section 115BBE is sustainable? 2. Whether the NFAC erred in confirming the addition of cash deposit, which was already shown as sales, resulting in double addition of gross sales? Assessee's Contentions: The cash deposited represented cash sales recorded in the regular books of account and offered to tax as part of gross turnover. Supporting documentary evidence, including the audit report, stock position, sales registers, cash book, and bank statements, was furnished to demonstrate that the cash deposits originated from recorded business transactions. Revenue's Contentions: The judgment records that the revenue's representative appeared but does not detail their specific arguments on the merits of the addition or the evidence presented by the assessee.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 147,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, C” BENCH, AHMEDABAD

Per Rahul Chaudhary, Judicial Member:

1.

The present appeal has been preferred by the Assessee against the Order, dated 24/03/2026, passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 20/03/2022, passed under Section 147 read with Section 144B of the Income Act, 1961 [hereinafter referred to as ‘the Act’] for the Assessment Year 2017-2018. 2. The Assessee has raised following grounds of appeal:

1.

NFAC erred in confirming addition made u/s 69A of the Act of

The order continues below.

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