PANKAJ JEWELLERS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-3(1)(1) OLD WARD-3(1)(2), AHMEDABAD
What did the Tribunal hold?
The Tribunal found that the assessee maintained regular books of accounts which were not rejected, and its sales and purchases were accepted as genuine. It concluded that the assessee had sufficient cash balance and adequately explained the source of cash deposits from recorded business operations, noting that the increased deposit ratio was primarily due to the demonetization scheme. Therefore, the addition made under Section 68 for unexplained cash credits was deemed unsustainable and ordered to be deleted.
What were the facts?
Pankaj Jewellers Pvt. Ltd., a bullion and jewellery trader, faced scrutiny for abnormal cash deposits during demonetization in AY 2017-18. The AO made an addition of Rs. 62,52,929/- under Section 68 for unexplained cash credits, based on a comparative analysis of the cash deposit to turnover ratio, which was subsequently confirmed by the CIT(A). The assessee contended that these deposits originated from its sufficient opening cash balance and cash sales, which were duly recorded in its books of account.
What were the issues?
Whether the addition of Rs. 62,52,929/- as unexplained cash credit under Section 68 during the demonetization period was justified, despite the assessee maintaining proper books of accounts and explaining the source of cash from recorded sales and opening balance.
Which sections of the Income-tax Act were involved?
Section 250,Section 143(3),Section 68,Section 154,Section 133(6),Section 115BBE
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD
Before: Shri Sanjay Garg & Shri Makarand V. Mahadeokar
Per Sanjay Garg, Judicial Member:
The present appeal has been preferred by the assessee against the order of the Commissioner of Income Tax (Appeals) passed under section 250 of the Income Tax Act, 1961, dated 16/06/2025, arising out of the assessment order passed by the Assessing Officer under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for the
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