INCOME TAX OFFICER, WARD-2(2)(1), GHAZIABAD, GHAZIABAD vs. NEW SHAKTI ABHUSHAN BHANDAR, GHAZIABAD

Brief facts of the case are that the assessee M/s. New Shakti Abhushan Bhandar is a partnership firm engaged in the business of trading, manufacturing (on job work basis) of gold and other ornaments (Jewelers). The assessee for the year under consideration e-filed its Return of Income on 29.10.2017 declaring income of Rs.27,76,260/-. The return was selected for assessment through CASS. The ld. AO noted that there was a cash deposit of Rs.2,21,36,500/- in its bank account during demonetization period. Unsatisfied with the explanation given by the assessee, the ld. AO proceeded to add an amount of Rs.82,40,000/- under section 69A of the Act. The ld. CIT(A) deleted the impugned addition. The Revenue is contesting the impugned relief accorded by the ld. CIT(A).

The ld. Sr. DR, Ankush Kalra, Sr. DR supported the order of the ld. Assessing Officer.

We have heard rival submissions in the light of material placed on record. The ld. Counsel for the assessee has invited our attention to the assessee’s paper book running into pages 224 containing copy of written submission filed before ld. CIT(A), extract of his books of account, reconciliation of sales and purchases, financial statements and cash deposits etc. The ld. Counsel placed reliance upon its VAT returns to buttress the point that the cash has direct linkages with the sale of the assessee. The Revenue could hardly dispute that the arguments of the assessee in all these supporting documents were specifically rebutted in the assessment proceedings. The fact however

In the result, the appeal of the assessee is party allowed.