Good Media News Pvt Ltd Vs ITO (ITAT Chandigarh)
The Chandigarh Bench of the Income Tax Appellate Tribunal considered an appeal by Good Media News Pvt Ltd against the order of the CIT(A) dated 23.12.2024 for AY 2017-18. The assessee, a private limited company engaged in providing Cable TV network services in Himachal Pradesh, deposited ₹3,72,79,775 in cash during the demonetisation period. It explained that the deposits represented business receipts from cable subscriptions, security deposits and installation charges, particularly arising from mandatory digitisation of cable television services and installation or replacement of digital set-top boxes.
The Assessing Officer accepted only ₹92,86,937 as reasonably available cash and treated ₹2,21,14,454 as unexplained cash credit under Section 68 of the Income-tax Act. The AO relied on the assessee’s normal cash generation and average cash balance and considered the claimed security deposits and installation charges disproportionate to the number of set-top boxes installed. The CIT(A) upheld the addition, while directing that the amount sustained under Section 68 be reduced from business turnover to avoid double taxation.
Before the Tribunal, the assessee submitted that the peculiar nature of its business and mandatory digitisation requirements resulted in substantial cash receipts. It also produced additional evidence, including subscriber agreements, details indicating increased subscriptions and documents concerning digital set-top box installations. The assessee sought another opportunity to establish the source of the deposits through subscriber-wise and other contemporaneous records.
