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ITAT Bangalore : Demonetisation Cash Deposits Cannot be Added u/s 68 When Supported by Books – GP Addition Deleted Without Defects in Accounts

Case Law Details

TaxGuru Citation
2026 taxguru.in 2148
Case Name
Suhas Ramesh Rao Rangadhol Vs ITO (ITAT Bangalore)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2017-18
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Suhas Ramesh Rao Rangadhol Vs ITO (ITAT Bangalore)

Assessee challenged addition of ₹33.20 lakh u/s 68 r.w.s 115BBE towards demonetisation cash deposits & GP addition of ₹94,903. AO treated SBN deposits as unexplained despite assessee showing cash balances across three proprietary concerns & offering sales in books.

ITAT held that assessee had sufficient cash on hand as on 09-11-2016 reflected in regular books & not disproved by AO. Mere deposit of existing cash during demonetisation cannot be treated as unexplained unless books are rejected or cash balance shown as fictitious. Further, once deposits are already recorded as sales & GP offered, separate addition u/s 68 is unjustified.

Regarding GP addition, Tribunal observed that books were audited & no defect was pointed out; AO cannot estimate higher margin merely based on presumed KSBC.

FULL TEXT OF THE ORDER OF ITAT BANGALORE

ITA No. 1912/Bang/2025 is filed by Sri Suhas Ramesh Rao Rangadhol (the Assessee/Appellant) for Assessment Year 2017-18 against the Appellate Order passed by the National Faceless Appeal Centre, Delhi (the Ld. CIT(A)) dated 17.06.2025 wherein the Appeal filed by the Assessee against the Assessment Order passed u/s. 143(3) of the Income Tax Act, 1961 by the Income Tax Officer, Ward-4, Shivamogga (the Assessing Officer), is dismissed.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,513

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