Suspicion Not Evidence: ITAT Strikes Down Addition Based on “Average Cash Deposit” Theory

DCIT Vs Sanjay Sales Agency (ITAT Delhi) Demonetisation Cash Deposits Explained from Books: Delhi ITAT Upholds Deletion of ₹12.20 Cr Addition- Suspicion ≠ Evidence: No Rejection of Books, No Stock Discrepancy—Cash Sales Cannot Be Taxed Again u/s 68 Assessee, a trader in pan masala & allied tobacco products, filed ROI declaring income of ₹1.01 crore. Search/survey was conducted on 29.03.2017. AO completed assessment u/s 143(3) by treating ₹12,20,50,000 out of SBN deposits during 09.11.2016–31.12.2016 as unexplained cash credit u/s 68 r.w.s 115BBE, based purely on an “average d...