A survey was conducted in the premises of the assessee. the AO held that it was a case of money laundering and a false impression had been created that the entire cash deposits in the bank account of the Assessee were purported sale proceeds. The AO also held that the entire cash deposits found in the bank account of the Assessee were, in fact unexplained income and not sale proceeds. It was held that that the quantum figure and the opening stock which stood accepted in the earlier years had to be taken as actual stock available with the Assessee. In view of these facts, the sales made by the Assessee out of its opening stock cannot not treated as unexplained income, to be taxed as income from other sources.
PCIT v. Akshit Kumar (2021) 197 DTR 121 /318 CTR 26 / 277 Taxman 423 (Delhi) (HC)
S. 68: Cash credits – Opening stock accepted in scrutiny – Sales made from opening stock cannot be treated as bogus. [S. 56, 133A]