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Probable Reasons as to why the new Rs. 2,000 notes are being issued and actions already being taken before demonetization:

I would like to explain why Rs 2,000 notes been issued in place of Rs 1,000 notes.

Let us simply take 2 Scenarios to understand this!

Scenario A: If  Rs. 2000 Note are not issued but only New Rs. 1000 Notes are issued.

Let’s say, for example Mr. X has Rs. 1,00,000/- black money in 100 Old Notes of Rs. 1000 each.

Mr. X divides that Rs. 1,00,000/- into 10 Equal Bundles, each comprising of 10 Old Notes of Rs.1000 each and puts each Stack on a Table.

On Day 1, in the morning Mr. X would deposit the first Bundle i.e. 10 Old Notes of Rs.1000 valued at Rs.10,000 into the bank and on same Day 1 in the Evening he would withdraw 10 New Notes of Rs. 1000 again valued at Rs. 10,000 and put it in the Locker in his house.

Now the real Game starts.

On Day 2: Morning, Mr. X would deposit the second bundle of 10 Old Notes of Rs. 1000 valued at Rs. 10,000 kept on the Table. However in his books of accounts submitted to Income Tax Department, he will show that he has deposited the same 10 New Notes which was withdrawn on Day 1 : Evening (which is actually still lying in the Locker of House)

On Day 2: Evening, Mr. X would again withdraw 10 New Notes of Rs. 1000 valued at Rs. 10,000/- and keep the same in Locker. So at the end of Day 2, Mr. X has Rs. 80,000 on Table in Old Notes and Rs. 20,000/- in New Notes in Locker.

Now Day 3 will come in next week as there is a limit of Rs. 20000 per week.

The same exercise shall continue till Day 10 and by the end of Day 10, Mr. X shall have no Old Notes and Rs. 1,00,000 in 100 New 1000 Rupee Note in the Locker.

However, to the Income Tax Department, Mr. X has shown that he was having only Rs. 10,000/- as black money initially (i.e. one bundle of 10 Notes of Rs. 1000) and he has rotated the same Rs. 10,000/- by depositing it into Bank account in the morning and withdrawing it in the evening and again depositing the same on next day and so on.

Thus, Mr. X has paid tax only on initial Rs. 10,000 whereas he has managed to convert all his Black money of Rs. 1,00,000 into new Notes.

This Modus operandi is called Peak theory i.e. theory of rotation of same money which is accepted by most of the High Courts and Tribunals.  Revenue is also helpless to catch Mr. X because the above scenario can also occur in genuine cases where you withdraw money from bank to purchase something and then when you think that no good deal is available, you may again deposit the same money into your bank account and are not required to pay tax again.

Scenario B:  Now if New Rs. 2000 Rupee Note instead of Rs. 1000:

Mr. X deposits first bundle of 10 Old Notes lying on Table in the Bank on Day 1 : Morning and then he withdraws 5 New Notes of Rs. 2000 on Day 1: Evening and keeps it in locker.

Now on Day 2 : Morning when he goes to deposit second bundle of 10 Old Notes of Rs. 1000 each and wrongly shows the Income Tax Department that he has redeposit the same money which was withdrawn on Day 1: Evening – Bingo !!!

He is caught red handed !! Because the Bank slip on Day 2 submitted to bank shows deposition of 10 Notes of Rs. 1000 each whereas the Govt knows that Mr. X could never have withdrawn on Day 1 any note of Rs. 1000 because they were never Printed !!

Now Isn't it really a Master Stroke by Mr. Narendra Modi, the beloved Prime Minister of our country ?

The above example also gives you an explanation as to why the withdrawal limit is kept so low because the above modus operandi can still be done with Rs. 500 note however, the incentive would be less because Mr. X cannot withdraw more than Rs. 10000/- in a day and even if he withdraws Rs. 10,000/-, there is every possibility that Banks shall give Mr. X,  2000 Rupee note. So Mr. X cannot follow the above modus operandi.

Each and every condition in the Notification is seen to take care of the problems likely to be faced by Citizens and at the same time making sure that such Sophisticated theories are not resorted to by Black money hoarders.

Now, what actions which were already taken in progress before demonetization of Old High Denomination notes:

PM Modi had a full blue print for the development of our country right from Day 1 of his being elected.

Firstly they asked for all the bank account number in your Return of Income

Then they linked your PAN with Aadhar

They linked all the subsidies, pension and other benefits directly to your bank account through Direct Benefit Transfer Scheme.

Then they gave opportunity to all the common men to open an account with bank through Jan Dhan Yojna

They entered into revised treaty with most of the countries in which unaccounted money goes through HAWALA e.g. Mauritius and thus the route of Black Money coming from Mauritius which everyone knew is stopped.

They passed few strict laws to overcome the evil of black money such as Benami Transaction Act and Foreign Black Money Act

They levied Excise duty on Gold.

They also made TCS compulsory for Cash transactions above 2 lakhs.

They withdrew lakhs of pending income tax and service tax litigations where Common men had won at Appeal level and Department had gone further.

They also entered into information exchange agreement with such countries.

Then they gave last opportunity to all black money hoarders through Income Declaration Scheme, 2016

Now they have a Scheme for Dispute Resolution Panel again to reduce Litigation till December 2016.

They also given an option to Black money evaders to declare there unaccounted income in Income Declaration Scheme.

Now the masterstroke, that they have banned Rs.500 &  Rs.1000 denominations.

Not only the destination of this whole process is commendable but even the journey or the chronology of these events is interesting which explains the ultimate destination and who knows , may be the journey is still not over.


So with the above explanation, it has already been cleared that this notification has been issued to eradicate black money from the economy. No doubt, with one single decision this will result in fighting against corruption, terrorism and enhancing digital payment (part of PM Modi vision of Digital India).

Please share the same on your WhatsApp and Facebook profile so that the nation could know the rationale behind the issuance of new notes.

Hope this article helped you.

Recommended read : Guidelines for replacement of Rupees 500 and 1000 notes


Published by

CA Keshav
(Student CA Final )
Category Income Tax   Report

23 Likes   191 Shares   60345 Views


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