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INCOME TAX APPELLATE TRIBUNAL (COCHIN BENCH)
INTURI RAMA RAO, AM, SONJOY SARMA, JM
ACIT, Corporate Circle-1(1), Kochi – Appellant
Versus
M/s. A. Geeri Pai Gold & Diamonds – Respondent
| Table of Content |
|---|
| 1. facts of case and tax assessment process. (Para 2 , 3) |
| 2. identification of key issues and decision reasoning. (Para 4 , 5) |
| 3. arguments presented for and against the tax assessment. (Para 6 , 7) |
| 4. court observations on evidentiary discrepancies and implications. (Para 8 , 9) |
| 5. final ruling and outcome of the proceedings. (Para 10 , 11) |
O R D E R
Per: Inturi Rama Rao, AM This appeal filed by the Revenue and the cross objection filed by the assessee are directed against the order of the National Faceless Appeal Centre, Delhi [CIT(A)] dated 25.08.2022 for Assessment Year (AY) 2017-18.
2. Brief facts of the case are that assessee is a partnership firm, engaged in the business of manufacture and retail trade of gold, diamond jewellery and silver articles. The return of income for the A.Y.2017-18 was filed on 30/10/2017 disclosing loss of Rs.4,13,30,105/-. Against the said return of income, the assessment was completed by the ACIT, Non-Corp Circle-1(1), Kochi (for short, 'AO')at a total income of Rs. 5,56,02,000/-. While doing so, the AO brought to tax the cash deposits made in specified bank notes (SBNs) made on 11/11/2016 of Rs. 1,50,00,000/-; on 12/11/2016 of Rs. 1,68,5
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