ITAT Surat says Receipt Followed by Matching Sales Cannot Be Entirely Treated as Unexplained Cash Credit

The ITAT Surat held that a receipt of ₹15 lakh followed by sales of an identical amount to the same party could not, in its entirety, be treated as an unexplained cash credit under Section 68. Given the transaction pattern, the statement relied upon by the Assessing Officer did not specifically implicate the assessee. The Tribunal restricted the addition to ₹90,000, representing 6% of the transaction value, based on the assessee's own offer to tax that amount. Importantly, the Tribunal expressly confined its decision to the peculiar facts and submissions in the case and stated that it should not be treated as a precedent.