J.R. Rice India (P) Ltd. v. ACIT (2023) 225 TTJ 69(UO) / 157 taxmann.com 337 (Delhi)(Trib)

S. 68 : Cash credits-Cash deposited in bank account-Demonetisation-Trading and processing of food grains-Maintained regular books of account-Addition is deleted.[ S.44AB, 115BBE]

Assessee-company is engaged in trading and processing of food grains. Assessee had made cash deposits of specified bank notes of certain amount in bank during demonetization period. Assessing Officer proceeded to make addition in respect of such cash deposits as unexplained cash credit under section 68 read with section 115BBE of the Act. Thee assessee is maintaining regular books of account which were duly subjected to statutory audit under Companies Act, 2013 and tax audit under section 44AB. Tribunal held that  cash deposits made by assessee were duly sourced by cash sales and recovery of trade debts from sundry debtors in cash, and hence, source of cash deposits were properly explained by assessee. To extent of cash sales made, corresponding stocks had been duly reduced in stock register. There is no reason to dispute to fact that cash deposits in bank account had been sourced out of either cash sales made by assessee during demonetization period or cash recoveries made from its customers prior to demonetization period, therefore addition made by Assessing Officer on account of same was unjustified and deleted. (AY. 2017-18)