ANANDA AQUA EXPORTS,GANAPAVARAM vs. INCOME TAX OFFICER, WARD-1, BHIMAVARM

I.T.A.No.15/VIZ/2025 Ananda Aqua Exports -- AY.2017-18 arising out of order passed under section 143(3) r.w.s. 147 of Income Tax Act, 1961 (in short ‘Act') dated 23.05.2023. 2. Brief facts of the case are that, assessee filed its return of income declaring a loss of Rs.2,22,563/-. The case was selected for scrutiny, for the reason, that the assessee has made cash deposits amounting to Rs.69,43,000/- during the demonetization period into the bank account of the assessee. Further, it was also observed that the total credits in the bank account is Rs.7,94,44,149/- whereas turnover declared by the assessee is Rs.5,59,44,879/-. Initially notice under section 148 of the Act was issued under un-amended provisions of the Act on 30.06.2021. Consequent to the directions of the CBDT vide Instruction 1/2022 dated 11.05.2022, notice issued under section 148 of the Act dated 30.06.2021 was deemed to be considered as show-cause notice under section 148A(b) of the amended Act. Considering the reply of the assessee dated 15.06.2022 order under section 148A(d) was passed on 26.07.2022 and notice under section 148 was issued on 26.07.2022. On a perusal of the submissions made by the assessee during t