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TMI Blog2022 (7) TMI 1559X X X X Extracts X X X X X X X X Extracts X X X X ..... r extant provisions, the assessee was permitted to accept demonetized currency till 24.11.2016 and the only reason to suspect the source of the same is the fact that the same was deposited on 29.11.2016. The adjudication of lower authorities overlooks the fact that the assessee deposited as much as Rs.49.12 Lacs out of which only an amount of Rs.0.46 Lacs is suspected to be unexplained income of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . The grounds taken by the assessee are as under: 1. The learned CIT(A) is not justified in sustaining the addition for a sum of Rs.46,000/-made originally by the AO u/s 69A r.w.s. 115BBE of the Act. 2. The reason stated by the CIT(A) to upheld the order is that the appellant did not bring any material on record to establish that the amount was out of his business receipts which is against the fac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ritten submissions. The Sr. DR justified the additions on the given factual matrix. Having heard rival submissions, our adjudication would be as under. 3. The assessee being resident firm is stated to be engaged as distributor of prepaid cards of BSNL on commission basis. During assessment proceedings, it transpired that the assessee deposited sum of Rs.49.12 Lacs in one of the accounts maintained ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ness receipts only. These notes could be deposited till 31.12.2016 provided the source of the same was explained by the assessee, The Specified Bank Notes (SBN) continued to be legal tender till 30.12.2016. However, rejecting the same, Ld. CIT(A) upheld the stand of Ld. AO against which the assessee is in further appeal before us. 5. Upon careful consideration of material facts, we find that as pe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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