“unexplained money”

Cash Credits & Unexplained ItemsSection 69ASection 69A5,888 judgments

The decision most relied on for unexplained money is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on unexplained money

(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48 · 2019 · Supreme Court

696

citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT

50 ITR 1 · 1963 · Supreme Court

581

citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT

37 ITR 288 · 1959 · Supreme Court

570

citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull

87 ITR 349 · 1973 · Supreme Court

525

citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Roshan Di Hatti v. CIT

107 ITR 938 · 1977 · Supreme Court

477

citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.

208 ITR 465 · 1994 · High Court

427

citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

Chuharmal v. CIT

172 ITR 250 · 1988 · Supreme Court

340

citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

Judgments citing unexplained money

Vikram Agrawal, Nagpur vs. ITO Ward 4(4), Nagpur

In the result, appeal is dismissed

ITA 319/NAG/2023[2015 16]Status: DisposedITAT Nagpur12 Dec 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke

Section 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Ramesh Keshwatkar, Hyderabad vs. Income Tax Officer, Ward-13(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1075/HYD/2024[2017-18]Status: DisposedITAT Hyderabad12 Dec 2024AY 2017-18

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1075/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18) Ramesh Keshwatkar Vs. Income Tax Officer Hyderabad Ward-13(1) [Pan :Adopk9626P] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.K.Gupta, Ar रधजस् व द्वधरध/Revenue By:: Ms.Reema Yadav,Dr सुिवधई की तधरीख/Date Of Hearing: 12/12/2024 घोर्णध की तधरीख/Date Of 12/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.08.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld. Cit(A)], Mumbai, Relating To A.Y.2017-18 On The Following Grounds : 1. In The Facts & Circumstances Of The Case, The Addition Of Rs.6,18,000/- Is Not Justifiable. 2. In The Facts & Circumstances Of The Case, The Ld.Cit(A) Ought To Have Closed The Proceedings Against The Deceased Person Especially When The Fact Of Death Of The Assessee Was Brought To The Notice Of Ld.Cit During The Pendency Of Appeal Proceedings.

For Appellant: Shri S.K.Gupta, ARFor Respondent: : Ms.Reema Yadav,DR

Section 69A

known sources of income like pension and the balance amount of the cash deposit of Rs.7,68,500/- is treated as unexplained money u/s 69A of the Income tax Act, 1961 (“the Act”). 3. Being aggrieved by the assessment order, the assessee preferred an appeal before the CIT(A). Before

Venkata Gurunatha Rao Swamy, Suryapet vs. ITO., Ward-1, Suryapet

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 1032/HYD/2024[2017-18]Status: DisposedITAT Hyderabad12 Dec 2024AY 2017-18

Bench: Shri Manjunatha G. (Accountant Member), Shri K. Narasimha Chary (Judicial Member)

For Appellant: Ms.S.Sandhya, ARFor Respondent: : Shri Srinath Sadanala, DR

Section 133ASection 143(2)

Assessing Officer had also made addition of Rs.1,77,77,000/- u/s 69A of the Act towards cash deposits during demonetization period. as unexplained money u/s 69A of the Act. The Assessing Officer also made additions of Rs.20,86,000/- towards stock difference noticed during the course of survey operations

ACIT Central Circle-1(2), Hyderabad vs. Satty and Associates, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 236/HYD/2022[2016-17]Status: DisposedITAT Hyderabad12 Dec 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.162 & 163/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2015-16 & 2018-19) Satty & Associates Vs. Assistant Commissioner Hyderabad Of Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.236/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2016-17) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) Cross Objection No.13/Hyd/2022 (Arising Out Of Ita No.236/Hyd/2022) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S Rama Rao, Ar (Appeared Through Virtual Mode)& Ms.S.Sandhya, Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 03/12/2024 घोर्णध की तधरीख/Date Of 12/12/2024 Pronouncement:

For Appellant: Shri S Rama Rao, ARFor Respondent: Shri Srinath Sadanala, DR

Section 132Section 153A

income filed for the relevant assessment year, the Assessing Officer made addition of Rs.8,53,048 (Rs.7,51,858/- + Rs.1,01,190/-) as unexplained money u/s 69A of the Act. 4. Being aggrieved by the order of the Assessing Officer, the assessee preferred an appeal before the Ld.CIT(A). Before

Satty and Associates, Hyderabad vs. ACIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 163/HYD/2022[2018-19]Status: DisposedITAT Hyderabad12 Dec 2024AY 2018-19

For Appellant: Shri S Rama Rao, ARFor Respondent: Shri Srinath Sadanala, DR

Section 132Section 153A

Satty and Associates, Hyderabad vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 162/HYD/2022[2015-16]Status: DisposedITAT Hyderabad12 Dec 2024AY 2015-16

For Appellant: Shri S Rama Rao, ARFor Respondent: Shri Srinath Sadanala, DR

Section 132Section 153A

Chand Singh Rajput, Shajapur vs. ITO, Shajapur

ITA 411/IND/2024[2011-12]Status: HeardITAT Indore12 Dec 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 139Section 143(3)Section 144Section 147Section 148Section 250

appellant to present his case. 4. The Id. CIT(A) was not justified in confirming the addition of Rs. 5,30,000/- against unexplained money on cash deposits. 5. The appellant carves leave to add, amend or modify any of the grounds of appeal.” 2. At the time of hearing

Mr. Waseem Ulla Khan, Tumkur vs. Income Tax Officer, Ward-1 & Tps, Tumkur

In the result, appeal of the assessee is allowed

ITA 1956/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Sri Ganesh R. Gale, Standing Counsel for Department

Section 115BSection 142Section 143Section 234Section 250Section 44ASection 68

Waseem Ulla Khan, Bangalore Page 4 of 9 demonetized notes should not be treated as undisclosed sources and unexplained money u/s.68 of the Act. 3.5 In response to the above notice / show cause, the assessee vide letter dated 12/12/2019 filed the copy of the cash book as on 08/11/2016

Arif Hussain, Bangalore vs. Income Tax Officer, Ward-6(3)(1), Bangalore

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 1274/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Dec 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Sri V. Narendra Sharma, A.RFor Respondent: Ms. Neha Sahay, D.R

Section 144Section 250Section 270ASection 27CSection 69A

Rs.2,22,93,326/- was treated as business receipts and accordingly the income computed by applying @ 8%, which comes to Rs.17,67,466/-. b) Unexplained money u/s 69A of the Act: As no explanation has been submitted for cash deposited to the extent of Rs.14,55,000/- during the demonetization ... period, the AO held the same as unexplained money u/s 69A of the Act. 3.1 On or before completion of assessment proceeding the AO also initiated penalty proceedings by observing that since the assessee has not furnished the return of income for AY 2017-18, despite having taxable income from

Sudhir Damji Bharani, Mumbai vs. ITO, Ward 27 (3)(1), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 4054/MUM/2024[2012-13]Status: DisposedITAT Mumbai12 Dec 2024AY 2012-13

Bench: Shri Amarjit Singh, Hon’Ble & Shri Rahul Chaudhary, Hon’Bleassessment Year: 2012-13 Sudhir Damji Bharani Ito, Ward-27(3)(1), Mumbai Flat No. 1302, Tower No. 8, Orchard Residency, Lbs Marg, Vs Behind R City Mall, Ghatkopar (West), Mumbai-400086. Pan: Aaapb 6726 C (Appellant) (Respondent)

For Appellant: Mr. Aditya RamchandranFor Respondent: Shri Uodal Raj Singh, Sr. DR

Section 132(4)Section 143(1)Section 147Section 148Section 153CSection 250(6)Section 69A

facts and circumstances of the case and in law, the Ld. CIT (A) has erred in confirming the addition of unexplained money amounting to 20,00,000 under Section 69A. 4. On the facts and circumstances of the case and in law, the Ld. CIT (A) has erred in confirming ... Since the assessee had not explained such cash loan transaction, therefore, the same was added to the total income of the assessee as unexplained money u/s 69A of the Act. 3 Sudhir Damji Bharani A.Y. 2012-13 3. The assessee filed appeal before the ld. CIT(A). However, the assessee

Mohammad Sajid, Barabanki vs. ITO-5(4), Barabanki

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 319/LKW/2024[2017-18]Status: DisposedITAT Lucknow11 Dec 2024AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Mohammad Sajid V. Income Tax Officer 5(4) Gram & Post Jahangirabad Barabanki Varabanki (U.P) Tan/Pan:Flyps5250Q (Appellant) (Respondent) Appellant By: Shri Shailendra Mishra, Advocate Respondent By: Shri Sunil Kumar Rajwanshi, D.R. Date Of Hearing: 05 12 2024 Date Of Pronouncement: 11 12 2024 O R D E R

For Appellant: Shri Shailendra Mishra, AdvocateFor Respondent: Shri Sunil Kumar Rajwanshi, D.R

Section 115BSection 142(1)Section 144Section 69A

before the AO. The Ld. A.R. also submitted that the AO was not justified in arbitrarily treating the Bank deposits of the assessee as unexplained money, without providing a reasonable opportunity to the assessee to explain the source thereof. The Ld. A.R., therefore, prayed that in the interest of justice

Pasupuleti Lakshmana Rao, Bhadrachalam vs. ITO., Ward-1, Kothagudem

In the result, appeal of the assessee is treated as allowed for statistical purposes

ITA 1198/HYD/2024[2017-2018]Status: DisposedITAT Hyderabad11 Dec 2024AY 2017-2018

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: NoneFor Respondent: Shri Reema Yadav, DR

Section 144Section 148Section 69A

assessing the total cash credits made into the bank account of the assessee during the demonetization period of Rs.18,09,500/- as unexplained money u/s 69A of the Act. 3. Against which, the assessee preferred an appeal before the CIT(A) and the learned CIT(A) upheld the order passed

M/S Sri Saravana Tyraders(Firm), Coimbatore vs. Iito, Non Corporate Ward-1(5), Coimbatore

Appeal of the assessee is allowed

ITA 380/CHNY/2024[2017-18]Status: DisposedITAT Chennai11 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.380/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017-2018) M/S. Sri Saravana Traders (Firm) Vs. The Income Tax Officer, S.F.No.54/2, Non Corporate Ward 1(5) Pichanur Village, Coimbatore 641 018 Navakkarai Post, Coimbatore 641 105. [Pan: Achfs 2783D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Yeshwanth Kumar, C.A., ""यथ" क" ओर से /Respondent By : Shri Ashwin D. Gowda, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 22.10.2024 घोषणा क" तार"ख /Date Of Pronouncement : 11.12.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri Yeshwanth Kumar, C.AFor Respondent: Shri Ashwin D. Gowda, IRS, Addl. CIT

Section 143(3)Section 68Section 69Section 69A

remaining amount of Rs.22,34,000/- [Rs.54,68,000 – Rs.32,34,213] as unexplained. Therefore, the ld. Assessing Officer added to the total income unexplained money of Rs.22,34,000/- u/s. 69A of the Act. Aggrieved, assessee preferred an appeal before the ld. CIT(A). 3. Before the ld.CIT ... cash deposited was out of business receipts during the demonetization is liable to be rejected. Assessee’s other contention was that the addition of unexplained money resulted in double taxation because the said amount was already part of the turnover disclosed. The ld.CIT(A) directed the ld. Assessing Officer

Sarosh Abdul Majid Zamindar, Bhiwandi vs. Assessing Officer Ward 1(4), Kalyan

ITA 5158/MUM/2024[2017-18]Status: DisposedITAT Mumbai11 Dec 2024AY 2017-18

Bench: Shri Narender Kumar Choudhry

Section 144ASection 250Section 44ASection 69A

were non-SBN deposited during demonetization period out of business receipts/sales. Somehow the Assessing Officer (AO) has treated the above deposits as unexplained money u/s 69A of the Act and made the addition of Rs.22,67,000/-. 6. On appeal, the Ld. Commissioner though deleted the addition of Rs.14

Ratnakar Merchandise Pvt. Ltd., Kolkata vs. ITO, Ward-4(1), Kolkata

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 850/KOL/2024[2016-17]Status: DisposedITAT Kolkata10 Dec 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 850/Kol/2024 Assessment Year: 2016-2017 Ratnakar Merchandise Pvt. Limited,…………Appellant C/O. Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata-700069 [Pan:Aadcr8555M] -Vs.- Income Tax Officer,……………………………...Respondent Ward-4(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Assessee Shri Kapil Mondal, Addl. Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 20, 2024 Date Of Pronouncing The Order: December 10, 2024 O R D E R

Section 147Section 148Section 69A

view of this, the said amount of Rs.25,00,000/- was added to the income returned u/s 69A of the Act as unexplained money of the assessee”. During the course of the appellate proceedings also, the appellant failed to respond to any of the notices issued inspite of availing reasonable

Sakthi Realty Holdings Pvt. Ltd., Coimbatore vs. DCIT, CC-2, Coimbatore

The appeal stand partly allowed in terms of our above order

ITA 1164/CHNY/2024[2017-18]Status: DisposedITAT Chennai10 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1164/Chny/2024 (िनधा)रण वष) / Assessment Year: 2017-18) M/S Sakthi Realty Holdings Ltd. Dcit बनाम/ #62, Dr. Nanjappa Road, Central Circle-2, Vs. Coimbatore-641 018. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeca-8414-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 20-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri R. Venkata Raman (CA) - Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -Ld. DR

these customers which largely remained un-served / un-responded. Considering the same, the amount of Rs.185 Lacs was treated as unexplained money of the assessee and added to its income. 5. During assessment proceedings, the assessee submitted that cash found was not separate income but part of receipts already taxed

Sri Arumuga Cottspin Pvt. Ltd., Coimbatore vs. The ACIT, CC-I, Coimbatore

The appeal stands partly allowed in terms of our above order

ITA 1098/CHNY/2024[2017-18]Status: DisposedITAT Chennai10 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1098/Chny/2024 (िनधा)रण वष) / Assessment Year: 2017-18) M/S. Sri Arumuga Cottspin Pvt. Ltd. Acit बनाम Sf No.919/6, No.2, Pollachi Road, Central Circle-1, / Vs. Ramanathapuram, Coimbatore-642 104. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aajcs-5065-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld. Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024

For Appellant: Shri R. Venkata Raman (CA) - Ld. ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) - Ld. DR

Section 133(6)Section 133ASection 143(3)Section 69A

Assessing Officer u/s.69A of the lncome-tax Act, 1961 ["Act"] treating cash deposits in the bank account during the demonetization period as unexplained money. 2. That the Ld.CIT(A) erred in not appreciating that the provisions of section 69A of the Act are not applicable to the facts and circumstances ... cash deposits of Rs.1902 Lacs were utilized by the assessee to settle bank borrowings. Accordingly, the sum of Rs.1902 Lacs was added as unexplained money u/s 69A. The assessee received advance of Rs.95.55 Lacs from M/s Mahasakthi Mills Ltd. which was also added protectively in the hands of the assessee

Sri Mahasakthi Mills Limited, Coimbatore vs. The ACIT, CC-I, Coimbatore

The appeal stands partly allowed in terms of our above order

ITA 1059/CHNY/2024[2017-18]Status: DisposedITAT Chennai10 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1059/Chny/2024 (िनधा)रण वष) / Assessment Year: 2017-18) Sri Mahasakthi Mills Limited Acit बनाम/ No.95/13, Vyshnav Building, Central Circle-1, Opp. Kg Cinemas, Race Course Road Coimbatore. Vs. Coimbatore-641 018. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcs-2111-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024 आदेश / O R D E R

For Appellant: Shri R. Venkata Raman (CA) - Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -Ld. DR

Section 133(6)Section 133ASection 143(3)Section 40A(3)Section 69A

Rs.12,67,55,000/-, made out of cash sales and realization from the Sundry Debtors in respect of sales already offered to tax, as unexplained money. 2. That the Ld.CIT(A) erred in not appreciating that the provisions of section 69A of the Act are not applicable to the facts ... rejected the aforesaid claims of the assessee and added the cash deposits as well as advances so made by the assessee as unexplained money u/s 69A. 6. The Ld. AR has explained that aggregate addition as made by Ld. AO for Rs.2067.60 Lacs has been sourced as under: - No. Particulars

Overseas Beverages Private Limited, Goa vs. ACIT Central Circle 1, Coimbatore

The appeal stand allowed in terms of our above order

ITA 1058/CHNY/2024[2017-18]Status: DisposedITAT Chennai10 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1058/Chny/2024 (िनधा)रण वष) / Assessment Year: 2017-18) M/S. Overseas Beverages Pvt. Ltd. Acit बनाम/ #11, Idc Honda Industrial Estate, Central Circle-1, Vs. Sattari, Goa-403 530. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-5591-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024 आदेश / O R D E R

For Appellant: Shri R. Venkata Raman (CA) - Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -Ld. DR

Section 131Section 143(3)Section 69A

treating cash deposits in the bank account, being bad debts recovered from the Sundry Debtors which has been duly offered as income, as unexplained money. 2. That the Ld.CIT(A) erred in not appreciating that the provisions of section 69A r.w.s 115BBE of the Act are not applicable ... assessee failed to explain the source of cash remittance into the bank accounts. Accordingly, the receipt of Rs.6.73 Crores was held to be unexplained money in the hands of the assessee. The assessee offered sum of Rs.5.73 Crores under PMGKY and accordingly, the balance amount of Rs.1 Crores was added

Nethravathi Distilleries P.Ltd, Kunigal vs. ACIT Central Circle 1, Coimbatore

ITA 1057/CHNY/2024[2017-18]Status: DisposedITAT Chennai10 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1057/Chny/2024 (िनधा)रण वष) / Assessment Year: 2017-18) M/S. Nethravathi Distilleries Pvt. Ltd. Acit बनाम/ #1, Bangalore Main Road, Central Circle-1, Avargere Village, Kunigal-572 130 Coimbatore. Vs. Karnataka. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacn-6939-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld. Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024 आदेश / O R D E R

For Appellant: Shri R. Venkata Raman (CA) - Ld. ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -Ld. DR

Section 131Section 143(3)Section 69A

account, made out of sales realization from the Sundry Debtors in respect of sales already offered to tax in the earlier assessment years, as unexplained money. 2. That the Ld.CIT(A) erred in not appreciating that the provisions of section 69A of the Act are not applicable to the facts ... assessee failed to explain the source of cash remittance into the bank accounts. Therefore, the deposits of Rs.29.50 Crores were held to be unexplained money u/s 69A. Shri Dhanakumar offered sum of Rs.5.40 Crores under PMGKY Scheme and the assessee offered another sum of Rs.2.60 Crores under the scheme. After