ZULU TELE SERVICES PRIVATE LIMITED,CHANDIGARH vs. INCOME TAX OFFICER, WARD - 1(4), CHANDIGARH
आयकर अपीलीय अिधकरण,चǷीगढ़ Ɋायपीठ,चǷीगढ़
IN THE INCOME TAX APPELLATE TRIBUNAL
DIVISION BENCH,‘SMC’,CHANDIGARH
BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER
आयकरअपीलसं./ITA No.1097/CHD/2024
िनधाŊरणवषŊ / Assessment Year : 2017-18
Zulu Tele Services Private
Limited
House No.3232,Sector 15-D,
Chandigarh.160015. बनाम
The ITO,
Ward 1(4),
Chandigarh.
̾थायीलेखासं./PAN NO: AAACZ1800C
अपीलाथŎ/Appellant
ŮȑथŎ/Respondent
( PHYSICAL HEARING )
िनधाŊįरतीकीओरसे/Assessee by : Sh.Parikshit Aggarwal, C.A.
राजˢकीओरसे/ Revenue by : Dr. Ranjit Kaur, Addl. CIT,Sr.Dr.
सुनवाईकीतारीख/Date of Hearing
:
26-05-2025. उदघोषणाकीतारीख/Date of Pronouncement
:
30-05-2025
आदेश/Order
The present appeal has been preferred by the assessee against the order dated 26-09-2024 passed by the Ld. Commissioner of Income
Tax,
National
Faceless
Appeal
Centre
(NFAC),
Delhi[hereinafter referred to as ‘CIT(A)’], for the Assessment Year
2017-18. 2. The Assessee in this appeal is aggrieved by the action of the CIT(A) in confirming the addition made by the Assessing Officer
(A.O.) of Rs. 30,23,500/-u/s 69A of the Income Tax Act, 1961 by 647-Chd-2023
Sher Singh, Yamunanagar treating the cash deposit in the bank account during the demonetization as income from unexplained sources.
3. Ld. counsel for the Assessee has submitted that the Assessee had deposited the amount of Rs. 30,23,500/ - in its bank account during the demonetization period in the month of October,
2016. Ld. counsel for the Assessee has referred to the various documents in the Paper Book to show that the Assessee had sufficient cash in hand and the assessee had to deposit the aforesaid amount in the bank account on the relevant date as the government had announced the demonetization scheme. Regarding the sources of the cash deposits, the Ld. counsel has demonstrated that during the relevant financial year, the assessee had adopted the new line of business i.e. man power service Provider. It has also been explained that the assesssee was required to keep the sufficient cash in hand for the purposes of disbursal of wages/salary to labour/employees working with the Assesssee.
4. The turnover of the Assesee for the year under consideration was increased to Rs. 8,53,37,339/-. as compared to immediately preceding year A.Y. 2205-16 of Rs. 49,31,608/- The Assessee during the year earned gross profit of Rs. 75,33,921/- and net profit of Rs. 53,89,619. The Ld. counsel has demonstrated that the 647-Chd-2023
Sher Singh, Yamunanagar assessee had sufficient cash in hand which was deposited by the Assessee because of the announcement of the demonetization scheme.
5. Ld. D.R. has not rebutted the aforesaid factual position.
6. In view of the above discussion, the impugned addition made/confirmed by the lower authorities is not sustainable and the same is ordered to be deleted.
7. In the result, the appeal of the Assessee stands allowed.
Order pronounced on 30-05-2025. (SANJAY GARG)
Judicial Member
आदेशकीŮितिलिपअŤेिषत/ Copy of the order forwarded to :
1. अपीलाथŎ/ The Appellant
2. ŮȑथŎ/ The Respondent
3. आयकरआयुƅ/ CIT
4. िवभागीयŮितिनिध, आयकरअपीलीयआिधकरण, चǷीगढ़/ DR, ITAT,
CHANDIGARH
5. गाडŊफाईल/ Guard File
आदेशानुसार/ By order,
सहायकपंजीकार/