Dy. CIT v. Baashyaam Constructions (P.) Ltd. (2025) 124 ITR 272 (Chennai)(Trib.)

S. 69A: Unexplained money-Cash deposits during demonetisation-Cash generated from additional income disclosed before Settlement Commission-Source explained-Addition deleted.

The assessee had disclosed additional income of Rs. 3.36 crores before the Settlement Commission in respect of bogus unsecured loan entries, and the Settlement Commission permitted capitalisation of the additional income. The assessee explained that the cash generated on repayment of those loan entries was utilised for working capital requirements and the balance cash available was deposited during the demonetisation period. The Tribunal held that the explanation was bona fide and reasonable. Merely because the cash had been used in the business as working capital did not mean that it ceased to be available as cash or cash equivalent. Accordingly, the source of the cash deposits stood satisfactorily explained, and the deletion of the addition under section 69A was upheld. (AY. 2017-18).

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