TMI Blog2023 (7) TMI 222X X X X Extracts X X X X X X X X Extracts X X X X ..... y notes (SBN) have been pumped into as unaccounted money? HELD THAT:- The instruction dated 21/02/2017 that the assessing officer basic relevant information e.g. monthly sales summary, relevant stock register entries and bank statement to identify cases with preliminary suspicion of back dating of cash and is or fictitious sales. The instruction is also suggested some indicators for suspicion of back dating of cash else or fictitious sales where there is an abnormal jump in the cases during the period November to December 2016 as compared to earlier year. It also suggests that, abnormal jump in percentage of cash trails to on identifiable persons as compared to earlier histories will also give some indication for suspicion. Non-availa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eived by assessee from its members during the demonetisation period in Specified Bank Notes. 3. The Ld.AR before us today has furnished the list of depositors, KYC documents of the depositors and cash book for the period 01.11.2016 to 18.11.2016 along with bank statements for the relevant period. It is submitted by the Ld.AR that except for a few depositors who expired during covid period KYC of the rest of the depositors have been furnished in the said paper book. All the above documents have been furnished before the authorities below which has not been duly verified. 4. The Ld.AR submitted that it accommodated its members by extending its services by accepting the money deposited by them. It is the submission of the assessee that n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assed by the authorities below. We have perused the submissions advanced by both sides in the light of records placed before us. 8. We have carefully considered the rival contention and perused the orders of the lower authorities. 9. Admittedly the assessee has deposited Rs. 33,75,500/- during the post-demonetization between 09/11/2016 and 30/12/2016. Therefore Ld.AO made addition of said amount as income of the assessee u/s. 68 of the income tax act, on the ground that the assessee ought not to have accepted SBN s which were no longer a legal tender. At the outset, we are of the view that the cash book and the confirmations filed by the assessee should have been verified. 9.1 We have carefully gone through the various standard ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... k dating of cash and is or fictitious sales. The instruction is also suggested some indicators for suspicion of back dating of cash else or fictitious sales where there is an abnormal jump in the cases during the period November to December 2016 as compared to earlier year. It also suggests that, abnormal jump in percentage of cash trails to on identifiable persons as compared to earlier histories will also give some indication for suspicion. Non-availability of stock or attempts to inflate stock by introducing fictitious purchases is also some indication for suspicion of fictitious sales. Transfer of deposit of cash to another account or entity, which is not in line with the earlier history. Therefore, it is important to examine whether th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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