Harishchandrasinh Pratapsinh Parmar Vs ITO (ITAT Ahmedabad)
Petrol pump cash sales explained: 69A & 115BBE addition deleted despite NFAC rejection of Rule 46A
ITAT Ahmedabad allowed assessee’s appeal & deleted addition of ₹2.07 crore made u/s 69A r/w 115BBE on account of cash deposits during demonetisation. Assessee, a petrol pump operator, demonstrated through quantitative stock records of petrol & diesel, purchase invoices from oil companies, VAT-wise sales registers, daily cash sales, stock valuation statements & bank statements that cash deposits were nothing but regular business receipts duly recorded in books. Tribunal held that once complete, internally consistent & corroborative records explaining source of deposits are produced, presumption of unexplained money u/s 69A does not survive. Even though CIT(A) had rejected additional evidence under Rule 46A, ITAT found material on record sufficient to establish nexus between sales & bank deposits & ruled that treating such business receipts as deemed income & taxing them u/s 115BBE was unsustainable. Accordingly, entire addition was deleted & appeal was allowed.
FULL TEXT OF THE ORDER OF ITAT AHMEDABAD
This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 29.06.2025 passed for A.Y. 2017-18.
