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3|Page ITA No.3609 & 4282/Del/2025 ii. After many reminders and after many opportunities given to the assessee to justify cash sales from 01010.2016 to 08.11.2016 it is found that proper reply along with relevant documents has not been submitted by the assessee and the documents/information which is submitted by the assessee also was found not supporting the queries raised, hence it is established that the sudden spike in the cash sales whose corresponding KYC was also not given by the assessee nor the justification was provided by the assessee w.r.t. sudden rise in cash sales in its case during the time of demonetization, hence it is established that the colourable device of cash sale was being used to bring the unaccounted money into the flow of economy and the cash sales were neither genuine nor real in any sense. These were only the accommodation entries being made by the assessee to carry out its business of colouring the black money to disguise it in form of real transaction. The entire money belonged to assessee itself.

iii. An abnormal increase in the percentage of cash sales during the period01a102016 to 08.112016 as compared to whole of the year:

It is found that from 01.04.2016 to 30.09.2016 only around 0.25% of total cash sale of F.Y- 2016-17 (total cash sale for F.Y 2016-17 was of Rs.8,53,73,622/-) was made by the assessee and from 09.1 1.2016 to 31.03.2017 also only 0.10% of total cash sale of F.Y.2016-17 (total cash sale for F.Y 2016-17 was of was made by the assessee. It means that almost around 99% cash sale of F.Y.- 2016-17 was made from 01010.2016 to 08.11.2016 (just before demonetization period). The facts and percentages which are coming are not tenable in any way. The question arises that how it is possible that during whole of the year no cash sale was made and only in 39 days (from 01010.2016 to 08.1 1.2016) iv. An abnormal increase in the percentage of cash sales during the F.Y.- 2016-17 as compared to last financial years:-

It is found on perusal of last two years data that in Y.- 2014-15 cash sale for whole of the year was 1.70% of total sale for the F.Y.- 2014-45, in F.Y.- 2015-16 also cash sale for whole of the year was just 2.60% of total sale for the F.Y.- However, during F.Y.2016-17 cash sale reached to almost 25% of total sale for the F.Y.- 2016-17 and further we observed that out of total cash sale for the year 2016-17, almost 99% sale was held between the period 01.10.2016 to 08.1 1.2016 (just before demonetization period). The facts and ratios which are coming are not tenable in any way.

Hence, in the absence of any information available the genuineness of such act especially during the time of demonetization is not proved whether revising of returns was due to accommodation of cash sale entries or otherwise.

viii. Unable to send various notices u/s 133(6) of Income tax Act:-

It has also been provided that while gathering material, section 1 '33(6) of the Act should be suitably invoked by the Assessing officers so as to gather additional information about persons, transactions and fund flow from the banks where the suspected transactions took place. Since no detail regarding customers has been provided by the assesssee so it was not possible to send notice u/s 133(6) to any person to whom assessee has sold goods during 01.10.2016 to 08.11.2016 and can assure about genuineness of the Transactions.