JCIT(OSD), CIRCLE 111, DEHRADUN, SUBHASH ROAD vs. M/S SURYANCHAL FURNITECH, BAHADRABAD INDUSTRIAL AREA, HARIDWAR

ITA 82/DDN/2025Status: DisposedITAT Dehradun21 January 2026AY 2017-18Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish Agarwal (Accountant Member)12 pages
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What did the Tribunal hold?

The Tribunal held that while the entire amount could not be treated as unexplained, a lump sum addition of Rs. 15,00,000/- was justified. The addition made by the Assessing Officer was deleted to the extent of Rs. 2,63,62,397/-, and Section 115BBE was not applied as the transactions were prior to April 1, 2017.

What were the facts?

The assessee deposited Rs. 2,78,62,397/- in cash during the demonetization period, claiming it was from cash sales to two parties. The Assessing Officer treated these deposits as unexplained cash credits as the parties were untraceable and their creditworthiness was not proven.

What were the issues?

Whether cash deposits made during demonetization, claimed as proceeds from cash sales, are unexplained cash credits. Applicability of Section 115BBE to transactions prior to April 1, 2017.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE

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Income Tax Appellate Tribunal, DEHRADUN BENCH, DEHRADUN

Before: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

Hearing: 15.01.2026Pronounced: 21.01.2026

Per Satbeer Singh Godara, Judicial Member:

This Revenue’s appeal for Assessment Year 2017-18, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2024-25/1074074259(1) dated 05.03.2025, in proceedings u/s 143(3) of the Income Tax Act, 1961. 2. Heard both the parties at length. Case file perused.

3.

Coming to the Revenue’s/appellant’s sole substantive ground raised herein, we note that it is aggrieved against the CIT(A)/NFAC’s lower appellate discussion reversing the Assessing Officer’s action treating the assessee’s cash deposits during demonetization amounting to Rs.2,78,62,397/- as 2 Suryanchal Furnitech unexplained cash credits u/s 68 r.w.s. 115BBE of the Act; readi

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