TMI Blog2025 (1) TMI 698X X X X Extracts X X X X X X X X Extracts X X X X ..... oducers/suppliers as middleman on commission basis and sold/supplied the same to retailers/shopkeepers. Besides the assessee produced before us the bank statement of ICICI Bank and evidences of cash deposited sale of fruits / receipt and thereafter, on account of Artiaz Services and withdrawal made against cash deposits. We find that there is hardly cash balance left in the bank account after payment to growers. T Thus, no doubt, that the receipt of money by the assessee is from sale of vegetables/ fruits as well as from Artiya Services for which the commission was charged by the assessee. The same cash deposits in the bank cannot be added to the income of the assessee on the ground that the assessee has shown less sales vis- -vis, the cash ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7; 32,00,500/- against the purchases of ₹ 15,52,770/-. Besides the assessee has shown commission income of ₹ 6,94,500/- for rendering his services as commission agent to the fruits/vegetables growers. During the impugned financial year, the assessee had deposited cash of ₹ 1,00,95,750/-, into ICICI bank account no. 501191. Accordingly, show cause notice was issued dated 05.09.2018, to explain the difference between the total cash deposits and the turnover shown which comes to around ₹ 62,00,750/- and why the same should not be treated as unexplained cash credit u/s 68 of the Act. According to the ld. AO, the assessee is liable for audit u/s 44AB of the Act as the turnover has exceeded the prescribed limit and accordi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sits to the tune of ₹ 1,00,95,750/- during the year, whereas the sales were only to the tune of ₹ 32,00,500/-. The contention of the assessee for this is that since, the assessee has acted as middleman on behalf of the growers therefore, it has procured the vegetables/ fruits from the growers and supplied the same to the consumers/retailers for which it has received cash payments in cash which were deposited into the bank account and thereafter the payments were made through bank to the suppliers. The ld. Authorized Representative submitted before us that so far as the providing of services as Artiya Services is concerned, the assessee has only charged commission for which the assessee has returned as commission income of ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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