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TMI Blog2025 (1) TMI 159X X X X Extracts X X X X X X X X Extracts X X X X ..... -2019. The grounds raised by the assessee read as under:- 1. The order dated 27.03.2024 of the Learned CIT(A) National Faceless Appeal Centre (NFAC) in ITA DIN & Order No: ITBA/NFAC/S/250/202324/1063483306(1) for the Assessment year AY 2017-2018 is contrary to facts, opposed to law and untenable. 2. The CIT-(A), NFAC failed to follow the Standard Operating Procedure as laid out by the CBDT in the instruction No.03/2017. 2.1 The Ld AO failed to follow the spirit of the instruction No.4/2017 and failed to follow the instructions of CBDT on Operation Clean Money Assessments 3. The Ld CIT-(A) erred in reproducing the assessment order and following the same without any basis, exhibiting non-application of mind on the strong grounds and s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eipts as unaccounted cash deposit u/s 69A and by this, making the appellant to suffer double addition of the same amount one is trade receipts already accounted and other the alleged addition made u/s 69A in the Assessment order 8. The Learned CIT-(A) erred in applying provisions of Section 115BBE of the Act in the facts and circumstances of the case of Appellant and determining the tax-liability as per the aforesaid section without appreciating that provisions of section 69A were not applicable in the facts of the case and, therefore. provisions of section 115BBE of the Act could not be invoked. As is evident, the sole issue that arises for our consideration is addition made by Ld. AO u/s 69A for cash deposited by the assessee during de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee u/s 69A. The Ld. CIT(A) confirmed the action of Ld. AO against which the assessee is in further appeal before us. Our findings and Adjudication 4. From the facts, it emerges that the assessee is engaged in wholesale and retail trade of grocery items and allied products which regularly generate cash inflows for the assessee. The only source of income for the assessee is trading activity. In support of its claim, the assessee had furnished bank account statement and cash book for this financial year. The cash receipts as earned out of sale proceeds have duly been accounted for in the books of accounts and the cash balance as available in the cash book has been sourced to make impugned deposits in the banks. The assessee has mai ..... X X X X Extracts X X X X X X X X Extracts X X X X
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