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2023 (4) TMI 269 - ITAT KOLKATAUnexplained cash deposits into bank accounts during demonetization period - unexplained money u/s 69A - benefit of Section 10(26AAA) available to the assessee - assessee has failed to substantiate the source of deposit - HELD THAT:- The assessee after availing exemption u/s 10(26AAA) reported Nil income.Assessee has submitted that the cash deposits in the various bank accounts were out of sales made in the proprietary business carried on under the name and style Royal Demazong and also out of realization from business debtors. Total cash deposits in the banks were to the tune of Rs. 20,10,000/- while the assessee made a turnover of Rs. 73,01,166/- during the year. In our opinion, the assessee has discharged his onus by placing the facts before the authorities below that the cash deposits were out of cash sales and realization from the sundry debtors from the proprietary business carried on by the assessee for which the license has been issued by the Municipal Corporation, Deorali, Sikkim. If we consider the quantum of cash deposits into bank accounts of the assessee and the quantum of the business of the assessee, then the explanation of the assessee seems to be reasonable and deserves to be accepted. Accordingly we reverse the order of Ld. CIT(A) and direct the AO to delete the addition. Appeal of the assessee is allowed.
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