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TMI Blog2024 (11) TMI 1311X X X X Extracts X X X X X X X X Extracts X X X X ..... made during demonetization period is not correct. The transactions have happened throughout the year and the nature of transaction is similar. Therefore, similar estimation could be made against demonetization deposit - AO is directed to adopt similar estimation of 5% against these deposits. - Hon ble Shri Manoj Kumar Aggarwal, AM And Hon ble Shri Manu Kumar Giri, JM For the Appellant : Shri. S. Sridhar, Advocate (Erode) For the Respondent : Ms R. Anita, IRS, Addl. CIT. ORDER PER MANU KUMAR GIRI (JUDICIAL MEMBER) This appeal by the assessee is directed against the order No.ITBA/NFAC/S/250/2023-2024/1062618166 (1) dated 14.03.2024 of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi. The assessment wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g Officer found that assessee maintained two account bearing numbers 028100050080118 and 0371500508000275 with Tamil Nadu Mercantile Bank, during the period from 01.04.2016 to 31.03.2017. The details of deposits for the period from 01.04.2016 to 31.03.2017 in the bank accounts were summarized as under. Sl.No Account No. Total cash Other credits other than demonetization period Cash deposit during demonetization 1 028100050080118 (SB Account) 3,29,059/- 2,00,000/- 2 0371500508000275 (Current Account) 2,06,06,303/- 11,63,500/- Total 2,09,35,362/- 13,63,500/- Since the assessee did not render any explanation for the above transactions of Rs. 2,09,35,362/- i.e., the cash and other transactions related to the period other than demonetization per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee is unable to adduce any records to substantiate the source of cash deposit. Considering the conduct of the assessee, Ld. AO estimated business income of 8% against normal deposits which was reduced to 5% by Ld. CIT(A). This estimation, in our considered opinion, is quite reasonable and the same, therefore, would not require any interference on our part. At the same time, artificial distinction created in deposits made during demonetization period is not correct. The transactions have happened throughout the year and the nature of transaction is similar. Therefore, similar estimation could be made against demonetization deposit of Rs. 13,63,500/-. The Ld. AO is directed to adopt similar estimation of 5% against these deposits. No ..... X X X X Extracts X X X X X X X X Extracts X X X X
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