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Old currency deposit under demonetization period

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(Querist)
08 April 2019 Mr A is doing trading business of non durable goods (ie. Garlic). He had deposited old currency of Rs. 32 lacs in his business account (current account) during the demonetization period. everyone well known demonetization implemented suddenly as per announcement by PM on evening dated 08.11.2016. Mr. A could not hold his stock till new currency come in market because his stock is non durable goods (garlic) gone to in wastage form and creditors increase. Mr A suffer huge loss they may be lost his business, goodwill, credit and all things. So Mr. A sold all his stock in old currency and deposit these old currency in his business account. As per IT Department Mr. A could not sale in old currency during demonetization. IT Department is considering said amount Rs. 32 lacs as income and computing tax on this amount under scrutiny u/s 143(3).
I am expecting from experts to give any reference or notification regarding above case to convince ITD to not consider Rs 32 lacs in computation of demand/Tax liability.
Thanks & Regard
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sudarshan

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sudarshan (Expert)
09 April 2019 there was ban on deposit of old currency.
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