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Explained SBN Deposits During Demonetization Not Unexplained Income: ITAT Mumbai

Case Law Details

TaxGuru Citation
2025 taxguru.in 5537
Case Name
Goldman Tapes Private Limited Vs ACIT (ITAT Mumbai)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2017-18
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Goldman Tapes Private Limited Vs ACIT (ITAT Mumbai)

Income Tax Appellate Tribunal (ITAT), Mumbai Bench, has delivered a significant ruling in the case of Goldman Tapes Private Limited Vs. ACIT, allowing the assessee’s appeal and directing the Assessing Officer (AO) to delete an addition of Rs. 44,61,000 made on account of cash deposits during the demonetization period (Assessment Year 2017-18). The Tribunal emphasized that a genuine explanation for the source of cash, even if in Specified Bank Notes (SBNs) after the demonetization announcement, cannot be rejected merely because the SBNs were no longer legal tender for general transactions.

The case originated from an intimation based on AIMS data concerning cash deposits of SBNs made by Goldman Tapes Private Limited in its bank accounts. The AO initiated scrutiny proceedings by issuing a notice under Section 142(1) of the Income Tax Act, 1961, on December 15, 2017. In response, the assessee filed its return of income and provided a detailed explanation for the cash deposits.

Goldman Tapes Private Limited contended that the cash, comprising SBNs, was received from existing debtors as realization of outstanding dues during the demonetization period. The assessee furnished comprehensive details, including names and addresses of these debtors, which the AO acknowledged in the assessment order.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,620

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