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2025 (1) TMI 698

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..... of cash deposit in ICICI Bank. 03. The facts in brief are that the assessee filed his return of income on 02.08.2016, by declaring total income at Rs. 2,92,240/-. The assessee engaged in the business of purchase and sale of vegetables and also acting as a commission agent on behalf of fruit suppliers/ growers. The case of the assessee was selected for limited scrutiny for verification of cash deposits into the bank account. Accordingly, the statutory notices were duly issued and served upon the assessee along with questionnaires. The assessee is a proprietor of Baba Lokenath Sahal Sabji Bhandar and total turnover disclosed by the assessee during the instant financial year were Rs. 32,00,500/- against the purchases of Rs. 15,52,770/-. Besi .....

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..... see has also made some purchases and sales of fruits and vegetables on his own account which were also shown in the profit and loss account of the assessee. Thus, the assessee has made purchases and sales on his behalf and also procured goods from producers/suppliers as middleman on commission basis and sold/supplied the same to retailers/shopkeepers. During the year the assessee has shown the total purchase of Rs. 15,42,770/- with corresponding sales of Rs. 32,00,500/-. Besides the assessee has shown commission income from the Artiya Services to the tune of Rs. 6,92,500/-. The ld. AO has made the addition because the assessee has made cash deposits to the tune of Rs. 1,00,95,750/- during the year, whereas the sales were only to the tune of .....

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..... tatement of ICICI Bank and evidences of cash deposited sale of fruits / receipt and thereafter, on account of Artiaz Services and withdrawal made against cash deposits. We find that there is hardly cash balance left in the bank account after payment to growers. Taking into account these facts of the case in totality, we have no doubt, that the receipt of money by the assessee is from sale of vegetables/ fruits as well as from Artiya Services for which the commission was charged by the assessee. The same cash deposits in the bank cannot be added to the income of the assessee on the ground that the assessee has shown less sales vis-à-vis, the cash deposit into the bank, whereas the assessee has shown the commission income from Artiya S .....

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