granted on payment of
Rs.56 lakhs. It also held that demonetization was not a force majeure event in
terms of the PPA. The Commission ... control of the appellant,
thereby constituting force majeure event which also includes
demonetization and delay in registration of land documents;
(c) extension of financial closure
recorded reasons for
selection pertains to "cash deposits during demonetization period",
whereas demonetization admittedly occurred during FY 2016-17
relevant ... Verification of agricultural income,
Return filed after 7.11.2016 and cash deposit during demonetization
period; and
Examination of cash deposits during demonetization.
The scope of enquiry
failed
to justify maintaining huge cash in hand just before announcement
of demonetization of SBN's.
2. That the grounds of appeal are without ... impugned amount represents the cash deposit
in SBN's during demonetization period from 08.11.2016 to 31.12.2016 in the
following manner:-
S. Bank details Cash
unexplained money being cash deposited in his bank
account during the demonetization period, by holding that the same to be out of
business receipts ... selection of case in scrutiny is Large value cash
deposits during demonetization period reported and undisclosed income
reported by PCIT (on ITBA AIMS Portal after
midnight, i.e. the date of announcement of
demonetization by the Central Government. The sworn statement recorded
during the course of survey proceedings that ... customer details. Since the sales made on 08.11.2016 following the
announcement of demonetization at 8 pm by the Hon'ble Prime Minister an
unprecedented
assessee's bank account
post demonetization. The assessee explained that the cash
was deposited partly out of the opening cash balance ... assessee had deposited cash of
Rs.2,12,56,500/- during the demonetization period in
the bank accounts. Assessing officer during the course
of assessment
assessee had made cash deposits aggregating to
Rs.34,95,500/- in demonetized currency during the period
09.11.2016 to 30.12.2016. The AO further noticed cash ... since the assessee was not authorized to accept the
demonetization currency subsequent to 08.11.2016.
4. As regards the claim of deduction
scrutiny on account of "Abnormal increase in cash deposits
during the demonetization period as compared to pre-
demonetization period."In this regard ... concocted
cash sale has been booked by the assessee just before the
demonetization period to adjust and to bring into books, its
undisclosed and unexplained
which Rs. 6,50,26,000/- was deposited
during the demonetization period. The Assessing Officer required the assessee to
furnish details of cash sales, customer ... been
claimed to small denomination legal tender received from sales in the
demonetization period. The AO found that as per upload
sudden rise in cash sales in its case during the time
of demonetization, hence it is established that the colourable device of cash
sale ... 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
