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2024 Supreme(Online)(ITAT) 851

INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
Vikram Singh Yadav, AM, Paresh M. Joshi, JM
KASTURI LAL LUDHIANA – Appellant
Versus
INCOME TAX OFFICER WARD-3 KHANNA KHANNA – Respondent


Advocates:
For the Assessee:Shri Tej Mohan Singh, Advocate
For the Revenue: Shri Vivek Vardhan, JCIT, Sr. DR

Table of Content
1. facts leading to the appeal regarding cash deposits. (Para 2 , 3)
2. legal argument surrounding cash deposits and business sales. (Para 4 , 5 , 6 , 8 , 10)
3. final adjudication and rationale for the verdict. (Para 12)
4. conclusion where the addition by the ao was deemed unsustainable. (Para 13)

आदेश/Order

PER VIKRAM SINGH YADAV, A.M. :

This is an appeal filed by the Assessee against the order of the Ld. CIT(A)/ NFAC, Delhi dt. 16/02/2024 pertaining to Assessment Year 2017-18.

2. In the present appeal, the Assessee has raised the following grounds of appeal:

“1. That the Ld. Commissioner of Income Tax (Appeals) has erred in upholding the addition of Rs.13,87,000/- made on account of alleged unexplained cash deposit of Specified Bank Notes in the bank account treating the same to be unexplained money of the assessee applying the provisions of Section 69A of the Act which is arbitrary and unjustified.

2. That the provisions of Section 69A are not attracted in as much as the entire business receipts including cash deposit of Rs. 13,87,000/- already stands declared in books on which taxes as applicable have been paid and as such treating Rs. 13,87,000/- to be unexplained

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