On appeal, the Tribunal held that, the assessee was an authorized money changer. This line of business required availability of cash in huge amounts as persons give dollars to be exchanged in Indian currency. The fact that the cash bundles carried the tag of PNB should not be given weightage as it was a common practice amongst all banks to issue currency bundles as received by them. Though the cash books were written on day-to-day basis, in practice there was always a time gap between the book entries. Further, not a single defect had been pointed out by the Assessing Officer in the books of account of the assessee when produced during assessment proceedings. The entire addition had been made on the basis of suspicions and surmises and such addition could not be sustained. (AY.2011-12)
R. G. Consultants P. Ltd. v. DCIT (2020) 78 ITR 37 (SN)(Delhi) (Trib)
S. 69 : Unexplained investments – Undisclosed cash — Money changer — Business requirements — Cash bundles carrying tag of another bank — Common practice — Cash books written day-to-day basis but in practice always a time gap between book entries — No defect pointed out by Assessing Officer in books of account of assessee — addition on basis of suspicion and surmises not justified.