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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Shri Vijay Pal Rao, VP, Shri Manjunatha, G., AM
SHARE MICROFIN LIMITED HYDERABAD – Appellant
Versus
DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1) HYDERABAD – Respondent
| Table of Content |
|---|
| 1. assessee's cash deposits during demonetization deemed unexplained. (Para 3 , 4 , 10) |
| 2. assessee's defenses regarding legality of transactions maintained. (Para 5 , 6 , 7 , 12) |
| 3. legal tender status directly impacts transaction legitimacy. (Para 8) |
| 4. court confirms ao's position based on demonetization notifications. (Para 9 , 11) |
आदेश/ORDER
Per Vijay Pal Rao, Vice President
This appeal filed by the assessee is directed against the order dated 31/07/2023 of the learned CIT (A)-NFAC Delhi, for the A.Y.2017-18.
2. The assessee has raised the following grounds:
3. The assessee is a Non-Banking Finance Company (NBFC) registered with the RBI and engaged in micro-finance business since 1999. The assessee filed its return of income for the year under consideration on 27/10/2017 declaring total income at “Nil”. The case was selected for scrutiny under CASS under complete scrutiny. During the scrutiny assessment proceedings, the Assessing Officer noticed that the assessee has made cash deposits to the tune of Rs.39,66,15,500/- in the bank account during the demonetization period in Specified Bank Notes (SBNs). The Assessing Officer asked the assessee to explain the source of t
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