Akash Anand Puri v. ITO (2025) 125 ITR 707 (Nagpur)(Trib.)

S. 69A: Unexplained money-Cash deposits in bank-Business receipts from sale of SIM cards and recharge vouchers-Addition under section 69A deleted-Profit element alone taxable- The Assessing Officer was directed to estimate the income at 1 per cent. of the gross business receipts, and no interest was leviable as the income remained below the basic exemption limit. [S. 144]

The Assessing Officer completed an ex parte reassessment and treated the entire cash deposits in the assessee’s bank account as unexplained money under section 69A. Before the Tribunal, the assessee produced bank statements, sales summaries and ledger accounts showing that the deposits represented business receipts from sale of SIM cards and recharge vouchers, which were continuously rotated for purchase of further stock. The Tribunal held that the Commissioner (Appeals) erred in ignoring the documentary evidence and merely relied upon the assessee’s non-compliance before the Assessing Officer. Since the nature and source of the deposits stood established, section 69A had no application. The Assessing Officer was directed to estimate the income at 1 per cent. of the gross business receipts, and no interest was leviable as the income remained below the basic exemption limit. (AY. 2017-18).

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