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Identity of the buyer was fully established/ in as much as tthe GST invoice issued shows the complete name and address of the buyer with his mobile number and all other relevant details being the description of the goods sold, the mode of transportation and other details. The periodical GST return for the month of June 2018 (PB-II 215-219)(submitted as an example) shows that invoices were raised in normal course of business much prior to the date of the survey i.e. 29.10.2018. The same was duly recorded in the sales ledger account as well. Thus, one fails to understand how explanation furnished by the assessee could be an afterthought or misleading or a case of fake story, as unfortunately the ld. CIT(A) repeatedly alleged but absolutely without any basis/ supporting evidences. Such a practice of abusing the citizen, has to be deprecated. 4.2. Sales declared before GST Department: Admittedly sales so made suffered GST and it is not the case of the Department that GST authorities have disbelieved the claimed sales. Interestingly, the AO itself happily taxed the profit arising from such sale offered through the net profit in the ROI. Once the sales has been declared, stands duly and fully established, assessed by the GST department and even accepted and taxed by the Income Tax Department, the cash realization therefrom, could not have been denied in any manner whatsoever. There is absolutely no convincing reason provided by the authorities below as why not to accept the sales so made. Very pertinently, there is absolutely not a single word whispered doubting the claim of the sales made. What to talk of establishing otherwise.

6. In addition to the above written submission, the ld. AR appearing on behalf of the assessee submitted that ;

"GOA 2: Addition of Rs.22,49,500/- on account of unexplained money u/s 69A:
(AO Pg. 7/CIT(A) Pg. 10, Pr. 4.2.6)
12. During the course of hearing, the Hon'ble Bench directed to submit copies of GST returns, etc. of which papers were submitted, and also tabulated, by way of 3rd paper book at Pg. 235 to 260. When asked, it was submitted that GST returns for the month of June, 2018 was filed on 07.08.2018 as evident from 3rd PB-249, further GST-R 3rd for the month of June, 2018 also shows the date of Turab Ali Bohra vs. ACIT filling of 03.08.2018. This was based on the various invoices issued for the month of June, 2018 for the total sale proceeds of Rs. 40,27,510.70/- and taxable value of Rs. 34,13,143.94/-. Duly reconciles with the summary of the complete invoices issued for this month 3rd PB - 235 to 241. For the month of July also, similar type of detailed ledger account of the various GST invoices was submitted. By these facts, it is established that the GST invoices were raised genuinely in the month of June & July, 2018, etc. and even the GST was paid/adjusted and the related GST-R 3B periodical returns were also filed in time, which was much before the survey/ requisition in October, 2019. The Ld. DR took support from the statement of the employee Shri Rathore and the assessee, reproduced in the assessment order and that both agreed that the sales consideration related to the sales made to these parties. For such contention, in fact, fully support the case of the assessee that the appellant made sales to these parties and also made collection from these very parties on account of the total sales of Rs. 22.47 lakh made to small fabricators, etc. Since these parties were common, hence there was a confusion to Department. Moreover, the statement were recorded in the absence of accountant (Q&A 11, PB-13), all these things were clarified on 19.09.2021 and we have elaborated in our WS. Answers given during requisition and survey statements cannot be expected to be correct with a mathematical precision as the presence of surcharged atmosphere cannot be ruled out. The appellant was 64 years at that time, yet the basic and substantive fact that it was the recovery made from these parties was duly explained.
sale invoices issued to small traders, fabricators and their ID proof. 5 Copy of written submission filed before CIT(A) dt. 27.07.2023 in response 183-184 to notice u/s 250 dt. 12.07.2023 6 Copy of acknowledgement of Reply dt. 20.09.2021 in response to notice 185-190 u/s 142 dt. 16.09.2021 6 Copy of Audited Balance Sheet, Trading A/c and Profit & Loss statement 191-198 for the F.Y 2018-19 (AY 2019-20) along with the accounts (Relevant extract only) 7 Copy of Tax Audit Report in Form 3CD for the F.Y 2018-19 (AY 2019-20) 199-214 (Relevant extract only) 8 Copy of GST Return being details of outward supplies made (Form 215-219 GSTR-1) for period June 2018 9 Copy of GST Return Summary of outward and inward supplies made 220-222 (Form GSTR-3B) for period June 2018 10 Copy of GST Reconciliation statement (Form GSTR-9C) for FY 2018-19 223-234 Another volume S. No. Particulars Page No. 1 Copy of Invoices/Vouchers list B2C (Small) for the period of June-July 235-248 2 Copy of GST Return being details of outward supplies made (Form 249-258 GSTR-1) for period June 2018 3 Copy of GST Return Summary of outward and inward supplies made 259A-260 (Form GSTR-3B) for period June-July 2018 Case laws relied upon:

During the statement recorded on 29.10.2018 before the Income Tax Officer investigation the source of cash has already been explained by the employee Sh. Shyam Singh Rathore. The ld. AR of the assessee placed on record all the details related to the sales made and the corresponding cash received on account of that cash sales. Lower authorities have disbelieved this fact merely on the ground that the cash were collected from different 9 parties. The assessee considered that cash collection center being his regular parties of the assessee, delegated by the assessee to collect the cash on his behalf. As is obvious Shri Shyam Sunder has given the statement based on the facts and he did not support his contention of cash collection center under the pressure of department did not categorically Turab Ali Bohra vs. ACIT and specifically that facts. Further details of sales bills for which the realization is recorded in the books of the assessee and that cash both cannot be added in the hands of the assessee. The ld. AR of the assessee filed a copy of sale of goods ledger and indirect tax return wherein invoices for which the realization is received is duly recorded. Thus, all these records categorically proved that the assessee is in receipt of proceeds of the sales reflected in the books of accounts and making separate addition of Rs. 22,49,500/- u/s 69A of the Act is duplicated addition of the sales recorded in GST return for the month of June, July, August and September filed.