ITAT Upholds Addition as Cash Hoarding Explanation Failed Human Probability Test

Patel Wines Vs DCIT (ITAT Ahmedabad) The appeal before the Income Tax Appellate Tribunal (ITAT), Ahmedabad, arose from the order of the Commissioner of Income Tax (Appeals) dated 27.08.2025 for Assessment Year 2017–18, wherein the addition of ₹1,61,37,212/- made by the Assessing Officer on account of cash deposits during the demonetization period was upheld. The assessee, a partnership firm engaged in the business of sale of liquor, had filed its return declaring income of ₹18,57,653/-. A survey under Section 133A was conducted on 17.03.2017. During assessment, it was observed that the a...