Tax Tribunal Rules on Cash Deposits: Peak Credit Approach for Income Assessment Prevails Over Blanket Classification.

The ITAT Delhi held that the CIT(A) erred in presuming all cash deposits as business receipts u/s 44AD. The CIT(A) treated deposits as business receipts and applied 8% net profit rate. The assessee argued for peak credits to be considered as income due to both deposits and withdrawals. The CIT DR sought to treat all cash deposits as undisclosed income without offsetting withdrawals, which was rejected. It was established that peak credit should be considered for undisclosed income when both credit and debit entries exist. The AO's addition of entire cash deposits without considering debit entries was deemed unjustified. The CIT DR failed to challenge the CIT(A)'s findings supported by the Investigation Wing's report on the assessee's business activity. The Revenue's grounds lacked merit and were dismissed. .....

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