Ramesh v. ITO (2025) 125 ITR 600 (Jodhpur)(Trib.)

S. 69A: Unexplained money-Cash deposits during demonetisation-Cash deposited directly by customers into bank account-Addition deleted.[S. 68, Specified Bank Notes (Cessation of Liabilities) Act, 2017, S. 2(1)(a), 5]

The assessee, engaged in the business of manufacturing and sale of textile goods, explained that the cash deposits during the demonetisation period represented sale proceeds directly deposited into his bank account by customers, which was the regular practice followed in earlier years. The Tribunal held that the sales were accepted as genuine and part of the cash deposits had already been accepted by the Department. The Reserve Bank of India guidelines imposed obligations only on the person making the deposit and not on the recipient. Since the specified bank notes continued to be legally depositable in banks up to 31 December 2016, direct deposits made by customers into the assessee’s bank account could not be treated as unexplained money under section 69A. The addition was accordingly deleted. (AY. 2017-18).

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