Raju Dinesh Kumar Vs DCIT (ITAT Chennai)
The appeal was filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 03.10.2023, for assessment year 2017-18.
The assessee, engaged in manufacturing dhalls such as toor dhall, orid dhall and moong dhall, had filed his return of income on 21.03.2018 declaring total income of Rs.10,46,030/-. The case was selected for scrutiny under CASS to examine substantial cash deposits during the demonetisation period.
During assessment proceedings, the Assessing Officer noted cash deposits of Rs.1,33,07,500/- in the assessee’s Axis Bank account between 09.11.2016 and 30.12.2016. The assessee explained that he purchased pulses in cash, manufactured dhalls and predominantly sold them for cash to unregistered dealers. He stated that the deposits represented opening cash in hand of Rs.71,76,208/- as on 08.11.2016 and cash sales during the relevant period. Comparative details of cash sales and bank deposits for FYs 2015-16 and 2016-17 were also furnished.
The Assessing Officer held that the assessee had not established the accumulation of Rs.71,76,208/- as cash in hand as on 08.11.2016. The AO also considered the receipt of demonetised currency after 08.11.2016 to be contrary to RBI and Government of India directions. The entire Rs.1,33,07,500/- was consequently added as unexplained money under Section 69A read with Section 115BBE of the Income-tax Act.
