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66,940 tribunal orders from the Delhi bench.
Counted from the judgments of this bench on BharatTax. The figure is how many of them cite each decision.
In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.
Appellate authorities can consider new claims and additional grounds if the relevant facts are already on record. The purpose of assessment is to correctly determine tax liability, allowing both parties to raise issues.
A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.
An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.
Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).
Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.
For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.
A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.
In search assessments under Section 153A, additions to income are permissible only if incriminating material is found during the search; in the absence of such material, completed assessments cannot be disturbed. A statement recorded under Section 132(4) and later retracted may not, on its own, constitute sufficient incriminating evidence for making additions.
An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.
Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.
Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.
A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.
The principle of consistency applies in tax matters, meaning a fundamental aspect found to be true in one assessment year should not be changed in a subsequent year if the order was not challenged.
For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.
Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.
A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.
When an income or expenditure is revenue neutral across different assessment years, where any benefit derived is offset by a corresponding liability or reversal, no additional tax liability arises, particularly concerning income recognition under the mercantile system of accounting.
The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.
Approval under Section 153D for search assessments is invalid if granted mechanically, hastily, or without due application of mind, such as on the same day as the proposal or in a bunched manner. Such an invalid approval renders the consequential assessment order under Section 153A void ab initio.
Most recent orders on record, from 2026.
The Tribunal noted that the assessee's appeal before the CIT(A)/NFAC was filed within a month of the assessment order. The Tribunal found that the CIT(A)/NFAC had not considered this fact. In the larger interest of justice, the Tribunal decided to restore the assessee's appeal back to the CIT(A)/NFAC for fresh adjudication on merits. The Tribunal directed that the assessee would have three effective opportunities to present its case, subject to the condition that the taxpayer shall plead and prove its case at its own risk and responsibility. The appeal was allowed for statistical purposes.
The Tribunal held that the CIT(A) correctly deleted the additions made by the Assessing Officer. The Tribunal noted that the loan of Rs. 1,00,00,000/- was taken through banking channels from M/s Saivi Finance Pvt. Ltd. and the entire repayment was also effected through proper banking channels. The ledger account showed an opening balance, reflecting continuity from prior years. Crucially, the repayment of the loan was made prior to the issuance of the reassessment notice dated 19.03.2024, and even before the search in the Galaxy group. The Tribunal relied on the jurisdictional ITAT's decision in Real Innerspring Technologies Pvt. Ltd. vs. ACIT, which dealt with substantially similar facts involving the same group of entry operators, and held that repayment of loans before the issuance of notice under Section 148 constituted genuine transactions. The Tribunal found that the assessee had repaid the loan along with interest, indicating genuine utilization and repayment. Therefore, the additions under Section 68, and consequential additions under Sections 69C and 36(1)(iii), were deleted. The grounds of appeal of the Revenue were rejected as devoid of merit.
The Tribunal held that the CIT(A) correctly deleted the additions made by the Assessing Officer. The Tribunal noted that the loan of Rs. 1,00,00,000/- was taken through banking channels from M/s Saivi Finance Pvt. Ltd. and the entire repayment was also effected through proper banking channels. The ledger account showed an opening balance, reflecting continuity from prior years. Crucially, the repayment of the loan was made prior to the issuance of the reassessment notice dated 19.03.2024, and even before the search in the Galaxy group. The Tribunal relied on the jurisdictional ITAT's decision in Real Innerspring Technologies Pvt. Ltd. vs. ACIT, which dealt with substantially similar facts involving the same group of entry operators, and held that repayment of loans before the issuance of notice under Section 148 constituted genuine transactions. The Tribunal found that the assessee had repaid the loan along with interest, indicating genuine utilization and repayment. Therefore, the additions under Section 68, and consequential additions under Sections 69C and 36(1)(iii), were deleted. The grounds of appeal of the Revenue were rejected as devoid of merit.
The Tribunal noted that the CIT(A) had dismissed the appeal ex-parte due to the assessee's absence and non-filing of written submissions, thereby confirming the AO's ex-parte assessment order. The assessee's representative requested the restoration of the matter to the file of the AO. The Tribunal, after examining the record and rival contentions, observed that the CIT(A) had dismissed the appeal in the absence of the assessee. In the interest of justice, the Tribunal set aside the impugned orders of the CIT(A) and the AO. The matter was restored to the file of the AO for a fresh decision in accordance with the law, after affording a fair opportunity of hearing to the assessee. The Tribunal did not decide on the merits of the grounds raised by the assessee, specifically regarding the classification of income and the validity of reopening.
The Tribunal noted that the Ld. CIT(A) had dismissed the assessee's appeal ex-parte, both on grounds of delay in filing before the CIT(A) and on merits. The assessee, described as a small farmer with limited knowledge of income tax law, had prayed for the restoration of the matter to the file of the AO. Considering the material facts and in the interest of justice, the Tribunal set aside the impugned orders of the Ld. CIT(A) dated 17.02.2025 and the penalty order dated 16.03.2022 of the Ld. AO. The matter was restored to the file of the Ld. AO for a fresh decision in accordance with law, after affording a fair opportunity of hearing to the assessee. The application for condonation of delay of 349 days in filing the appeal before the Tribunal was allowed. The appeal filed by the assessee was allowed for statistical purposes. The Tribunal did not decide the substantive issues raised by the assessee on merits.
The Tribunal held that the learned CIT(A) had indeed violated the principles of natural justice. It found that the assessee was not afforded a proper opportunity to present its case, and a personal hearing, which was specifically requested, was denied. The Tribunal reasoned that adherence to natural justice is a fundamental requirement for any quasi-judicial authority. By failing to provide a fair hearing, the CIT(A) committed a significant procedural error. Consequently, the Tribunal set aside the order of the CIT(A) and remanded the matter back to the CIT(A) for fresh adjudication. The CIT(A) was directed to grant the assessee a reasonable opportunity of being heard and to pass a fresh order in accordance with law. The issue regarding the merits of the assessment was not decided by the Tribunal.
The Tribunal held that the CIT(A) had given credence to the assessee's books and reconciliations regarding sundry creditors. The CIT(A) found that after remand, the assessee explained Rs. 4,52,35,342/- out of Rs. 6,67,34,790/-, leaving Rs. 2,14,99,448/- unexplained. The CIT(A) then restricted the disallowance to 20% of this disputed amount, i.e., Rs. 42,99,890/-, as an estimate for any unverifiable portion. The Tribunal found no reason to interfere with this decision and dismissed the grounds of both the Revenue and the Assessee on this issue. Regarding the deletion of interest on advances to a group concern and the disallowance of sundry debtors write-back, the Tribunal found the CIT(A)'s decisions to be reasonable. For the deduction under section 80-IB(4), the Tribunal noted that the Revenue had not rebutted the CIT(A)'s findings that the assessee was eligible, had a unit in a notified area, and was manufacturing a specified product. Therefore, the Tribunal found no error in allowing the claim under section 80-IB(4)/80-IA and dismissed the Revenue's grounds. The operative direction was that both appeals were dismissed.
The Tribunal held that the penalty proceedings, though separate, can be challenged based on the validity of the assessment order, especially when the penalty is founded on allegations of concealment of income. The Tribunal noted that the AO of the searched person recorded satisfaction on 22.07.2022, and the AO of the assessee recorded satisfaction on 03.03.2023, issuing a notice under Section 153C on the same date. The Tribunal found that the assessment year 2014-15 falls beyond the six-year period permissible under Section 153C, considering the satisfaction date. Relying on the case law cited by the assessee, the Tribunal concluded that the foundation of the assessment order was vitiated. Consequently, the penalty proceedings were held to be void-ab-initio and liable to be set aside. The appeal of the assessee was allowed, and the impugned penalty was quashed.
The Tribunal allowed the appeal, quashing the impugned assessment order. The Tribunal found that the original assessment under section 143(3) had already examined business expenses, including purchases from M/s Global Vision. The reopening was based on information from the investigation wing alleging bogus accommodation entries of Rs. 1,92,79,900/- through payments to Shera Kashyap. However, the show cause notice and consequential order under section 148A(d) lacked specificity regarding the nature of expenses, dates of payments, and bank details, indicating a non-application of mind by the AO. The Tribunal held that the reopening was based on vague information and a change of opinion, citing several Supreme Court and Delhi High Court decisions. The absence of vital information in the reasons for reopening vitiated the proceedings, as the AO could not form a belief that income had escaped assessment. The Tribunal also noted that the AO incorrectly stated in the order under section 148A(d) that no prior assessment was made, despite being aware of the section 143(3) assessment, indicating a failure to verify records. Consequently, grounds 1 and 2 were sustained, rendering other grounds academic. The assessment order was quashed.
The Tribunal held that the addition of Rs. 26,35,000/- on account of cash deposited during the demonetization period was not justified. The Tribunal found that the AO's reliance solely on the alleged unusual surge in cash sales was insufficient, especially when the assessee had provided material evidence such as stock and sales statements, VAT returns, month-wise cash sales and deposits, and copies of bills. The Tribunal noted that the assessee demonstrated a growth in both credit and cash sales compared to the previous year, negating the allegation of an abnormal increase. The Tribunal concluded that making an addition on mere suspicion was not justified, given the nature of the assessee's business and the corresponding increase in sales during the festival season. Regarding the addition of Rs. 7,52,667/- on account of the difference in purchases, the Tribunal held that the assessee complied with Accounting Standard 11 and Section 145(2) of the Act by using the exchange rate on the date of payment for foreign creditors. The Tribunal found no mismatch requiring further reconciliation, as the difference arose from the timing of valuation. Consequently, the grounds were decided in favour of the assessee.
The Tribunal noted that the period for condoning delays due to Covid-19 had expired, and even excluding this period, there was a significant delay. The assessee failed to provide sufficient evidence for the reasons cited for the delay.
The Tribunal held that the issue of taxability of interest on compensation, particularly for agricultural land, is a debatable and controversial issue. While acknowledging that various judicial pronouncements exist, the Tribunal noted that the jurisdictional High Court of Punjab and Haryana has decided the issue against the assessee in cases like "Mahender Pal Narang" and "Puneet Singh". The Tribunal found that the CIT(A) correctly held that the issue was not amenable to rectification under Section 154 as it was debatable and not a "mistake apparent from record". The Tribunal agreed with the CIT(A)'s reasoning that the assessee had failed to claim the exemption in the original return or a revised return, and Section 154 cannot be used to make a fresh claim or rectify omissions that require further investigation. Therefore, the appeals were dismissed. No issue was expressly left undecided.
The Tribunal held that the assessee had successfully discharged the three ingredients of Section 68 of the Income Tax Act, 1961: identity of the lenders, creditworthiness of the lenders, and genuineness of the transactions. The Tribunal noted that the assessee had furnished bank statements, audited financial statements, ITR acknowledgments, and certified ledger accounts of the lender companies. Furthermore, the lenders had complied with notices issued under Section 133(6) of the Act, and no discrepancies were pointed out by the AO. The Tribunal also observed that the loans had been fully or partly repaid. Crucially, the Tribunal relied on multiple previous ITAT orders that had already adjudicated similar issues concerning loans received from the impugned lender companies, finding them to be genuine and deleting additions made under Section 68. These prior decisions covered almost all the six lender parties in question. The Tribunal found no infirmity in the CIT(A)'s order, which placed reliance on these Tribunal orders. Consequently, the grounds raised by the revenue were dismissed for all years. The cross-objections filed by the assessee were dismissed as infructuous, being supportive of the CIT(A)'s order. Appeals related to AY 2015-16 were dismissed as duplicate. The operative direction was to dismiss the revenue's appeals and the assessee's cross-objections.
The Tribunal admitted the additional ground of appeal as it was purely legal. Regarding the jurisdiction of the AO, the Tribunal observed that while the Section 143(2) notice initially specified two issues (dividend income and expenses for earning exempt income), the case was selected for complete scrutiny. The Tribunal held that once a case is selected for complete scrutiny, it is open for the AO to enlarge the scope of assessment by examining issues other than those initially informed in the Section 143(2) notice. The Tribunal found no infirmity in the AO's order in making disallowances out of various expenses claimed by the assessee, dismissing the additional ground of appeal. For grounds 2 to 9, concerning disallowances of gratuity, 7th Pay Commission provision, CBS expenses, staff salary, leave encashment, consultancy fee, and interest subvention, the Tribunal noted that the assessee failed to file proper explanations and documentary evidence before the lower authorities. Therefore, the Tribunal set aside the orders of the lower authorities and remanded the matter to the AO for fresh examination, directing the assessee to appear and provide all necessary details and evidence. These grounds were allowed for statistical purposes.
The Tribunal held that the assessee had successfully discharged the three ingredients of Section 68 of the Income Tax Act, 1961: identity of the lenders, creditworthiness of the lenders, and genuineness of the transactions. The Tribunal noted that the assessee had furnished bank statements, audited financial statements, ITR acknowledgments, and certified ledger accounts of the lender companies. Furthermore, the lenders had complied with notices issued under Section 133(6) of the Act, and no discrepancies were pointed out by the AO. The Tribunal also observed that the loans had been fully or partly repaid. Crucially, the Tribunal relied on multiple previous ITAT orders that had already adjudicated similar issues concerning loans received from the impugned lender companies, finding them to be genuine and deleting additions made under Section 68. These prior decisions covered almost all the six lender parties in question. The Tribunal found no infirmity in the CIT(A)'s order, which placed reliance on these Tribunal orders. Consequently, the grounds raised by the revenue were dismissed for all years. The cross-objections filed by the assessee were dismissed as infructuous, being supportive of the CIT(A)'s order. Appeals related to AY 2015-16 were dismissed as duplicate. The operative direction was to dismiss the revenue's appeals and the assessee's cross-objections.
The Tribunal held that the assessee had successfully discharged the three ingredients of Section 68 of the Income Tax Act, 1961: identity of the lenders, creditworthiness of the lenders, and genuineness of the transactions. The Tribunal noted that the assessee had furnished bank statements, audited financial statements, ITR acknowledgments, and certified ledger accounts of the lender companies. Furthermore, the lenders had complied with notices issued under Section 133(6) of the Act, and no discrepancies were pointed out by the AO. The Tribunal also observed that the loans had been fully or partly repaid. Crucially, the Tribunal relied on multiple previous ITAT orders that had already adjudicated similar issues concerning loans received from the impugned lender companies, finding them to be genuine and deleting additions made under Section 68. These prior decisions covered almost all the six lender parties in question. The Tribunal found no infirmity in the CIT(A)'s order, which placed reliance on these Tribunal orders. Consequently, the grounds raised by the revenue were dismissed for all years. The cross-objections filed by the assessee were dismissed as infructuous, being supportive of the CIT(A)'s order. Appeals related to AY 2015-16 were dismissed as duplicate. The operative direction was to dismiss the revenue's appeals and the assessee's cross-objections.
The Tribunal held that while the assessee had failed to furnish the requisite details despite an opportunity, the CIT(E) had not recorded any specific adverse finding that the trust's objects were not charitable or that its activities were not genuine. The rejection was based on the inability to verify the conditions due to a lack of supporting material. The Tribunal acknowledged the assessee's onus to substantiate its eligibility but, in the interest of substantial justice, decided to grant the assessee one more opportunity. The impugned order was set aside, and the matter was restored to the CIT(E) for fresh adjudication. The assessee was directed to cooperate and furnish all required documents. The Tribunal explicitly stated that it was not expressing any opinion on the merits of the assessee's eligibility for registration. The appeals were allowed for statistical purposes.
The Tribunal held that the assessee had successfully discharged the three ingredients of Section 68 of the Income Tax Act, 1961: identity of the lenders, creditworthiness of the lenders, and genuineness of the transactions. The Tribunal noted that the assessee had furnished bank statements, audited financial statements, ITR acknowledgments, and certified ledger accounts of the lender companies. Furthermore, the lenders had complied with notices issued under Section 133(6) of the Act, and no discrepancies were pointed out by the AO. The Tribunal also observed that the loans had been fully or partly repaid. Crucially, the Tribunal relied on multiple previous ITAT orders that had already adjudicated similar issues concerning loans received from the impugned lender companies, finding them to be genuine and deleting additions made under Section 68. These prior decisions covered almost all the six lender parties in question. The Tribunal found no infirmity in the CIT(A)'s order, which placed reliance on these Tribunal orders. Consequently, the grounds raised by the revenue were dismissed for all years. The cross-objections filed by the assessee were dismissed as infructuous, being supportive of the CIT(A)'s order. Appeals related to AY 2015-16 were dismissed as duplicate. The operative direction was to dismiss the revenue's appeals and the assessee's cross-objections.
The Tribunal held that the assessee had successfully discharged the three ingredients of Section 68 of the Income Tax Act, 1961: identity of the lenders, creditworthiness of the lenders, and genuineness of the transactions. The Tribunal noted that the assessee had furnished bank statements, audited financial statements, ITR acknowledgments, and certified ledger accounts of the lender companies. Furthermore, the lenders had complied with notices issued under Section 133(6) of the Act, and no discrepancies were pointed out by the AO. The Tribunal also observed that the loans had been fully or partly repaid. Crucially, the Tribunal relied on multiple previous ITAT orders that had already adjudicated similar issues concerning loans received from the impugned lender companies, finding them to be genuine and deleting additions made under Section 68. These prior decisions covered almost all the six lender parties in question. The Tribunal found no infirmity in the CIT(A)'s order, which placed reliance on these Tribunal orders. Consequently, the grounds raised by the revenue were dismissed for all years. The cross-objections filed by the assessee were dismissed as infructuous, being supportive of the CIT(A)'s order. Appeals related to AY 2015-16 were dismissed as duplicate. The operative direction was to dismiss the revenue's appeals and the assessee's cross-objections.
The Tribunal held that the assessee had successfully discharged the three ingredients of Section 68 of the Income Tax Act, 1961: identity of the lenders, creditworthiness of the lenders, and genuineness of the transactions. The Tribunal noted that the assessee had furnished bank statements, audited financial statements, ITR acknowledgments, and certified ledger accounts of the lender companies. Furthermore, the lenders had complied with notices issued under Section 133(6) of the Act, and no discrepancies were pointed out by the AO. The Tribunal also observed that the loans had been fully or partly repaid. Crucially, the Tribunal relied on multiple previous ITAT orders that had already adjudicated similar issues concerning loans received from the impugned lender companies, finding them to be genuine and deleting additions made under Section 68. These prior decisions covered almost all the six lender parties in question. The Tribunal found no infirmity in the CIT(A)'s order, which placed reliance on these Tribunal orders. Consequently, the grounds raised by the revenue were dismissed for all years. The cross-objections filed by the assessee were dismissed as infructuous, being supportive of the CIT(A)'s order. Appeals related to AY 2015-16 were dismissed as duplicate. The operative direction was to dismiss the revenue's appeals and the assessee's cross-objections.
The Tribunal held that the assessee had successfully discharged the three ingredients of Section 68 of the Income Tax Act, 1961: identity of the lenders, creditworthiness of the lenders, and genuineness of the transactions. The Tribunal noted that the assessee had furnished bank statements, audited financial statements, ITR acknowledgments, and certified ledger accounts of the lender companies. Furthermore, the lenders had complied with notices issued under Section 133(6) of the Act, and no discrepancies were pointed out by the AO. The Tribunal also observed that the loans had been fully or partly repaid. Crucially, the Tribunal relied on multiple previous ITAT orders that had already adjudicated similar issues concerning loans received from the impugned lender companies, finding them to be genuine and deleting additions made under Section 68. These prior decisions covered almost all the six lender parties in question. The Tribunal found no infirmity in the CIT(A)'s order, which placed reliance on these Tribunal orders. Consequently, the grounds raised by the revenue were dismissed for all years. The cross-objections filed by the assessee were dismissed as infructuous, being supportive of the CIT(A)'s order. Appeals related to AY 2015-16 were dismissed as duplicate. The operative direction was to dismiss the revenue's appeals and the assessee's cross-objections.
The Tribunal held that while the assessee had failed to furnish the requisite details despite an opportunity, the CIT(E) had not recorded any specific adverse finding that the trust's objects were not charitable or that its activities were not genuine. The rejection was based on the inability to verify the conditions due to a lack of supporting material. The Tribunal acknowledged the assessee's onus to substantiate its eligibility but, in the interest of substantial justice, decided to grant the assessee one more opportunity. The impugned order was set aside, and the matter was restored to the CIT(E) for fresh adjudication. The assessee was directed to cooperate and furnish all required documents. The Tribunal explicitly stated that it was not expressing any opinion on the merits of the assessee's eligibility for registration. The appeals were allowed for statistical purposes.
The Tribunal held that the issue of taxability of interest on compensation, particularly for agricultural land, is a debatable and controversial issue. While acknowledging that various judicial pronouncements exist, the Tribunal noted that the jurisdictional High Court of Punjab and Haryana has decided the issue against the assessee in cases like "Mahender Pal Narang" and "Puneet Singh". The Tribunal found that the CIT(A) correctly held that the issue was not amenable to rectification under Section 154 as it was debatable and not a "mistake apparent from record". The Tribunal agreed with the CIT(A)'s reasoning that the assessee had failed to claim the exemption in the original return or a revised return, and Section 154 cannot be used to make a fresh claim or rectify omissions that require further investigation. Therefore, the appeals were dismissed. No issue was expressly left undecided.
For AY 2003-04, the Tribunal dismissed the Revenue's appeal on Ground No. 8 concerning the disallowance of advertisement expenses. The Tribunal noted that the expenditure was incurred for the 'Sahara' brand and was shared among group entities based on a prior understanding with the Income Tax Department in AY 1996-97, which was accepted by the group concern. The Tribunal found that the direct nexus between the expenditure and the assessee's business was established through the prominent display of the 'Sahara' brand. The CIT(A)'s deletion of the addition was upheld. The Tribunal also stated that all other contents of its earlier order for AY 2003-04, except for Ground No. 8, would remain unchanged. The appeal of the Revenue was dismissed. The judgment does not contain specific findings or reasoning for AY 2004-05 regarding the newsprint wastage issue, other than noting the Revenue's appeal and the AO's arbitrary adoption of a 6% wastage rate. The operative direction for AY 2003-04 was dismissal of the revenue's appeal.
The Tribunal partially allowed the assessee's appeal. Regarding the cash deposits of Rs. 13,35,000/- during the demonetization period, the Tribunal found that while the assessee had not fully discharged the onus of proof, a lumpsum addition of Rs. 1.5 lakhs would be just and proper. This provided the assessee with relief of Rs. 11,85,000/-. The Tribunal explicitly stated that this relief shall not be treated as a precedent. Concerning the assessment under section 115BBE, the Tribunal, relying on the Madras High Court decision in S.M.I.L.E. Microfinance Ltd. Vs. ACIT, held that this provision would only come into effect for transactions done on or after 01.04.2017. Therefore, the assessee was directed to be assessed under the normal provisions of the Act. No other grounds were pressed.