Revenue's appeal dismissed as additions under sections 69A, 69C, and 68 deleted due to insufficient evidence and proper documentation by assessee.

ITAT Mumbai dismissed revenue's appeal in case involving additions under sections 69A, 69C, and 68. Regarding section 69A addition based on loose sheets showing cash amounts, ITAT upheld CIT(A)'s direction to AO to verify if sales from loose sheets appear in books of M/s. Samaira Enterprises to avoid double taxation. For section 69C additions on unaccounted purchases, ITAT confirmed deletion as assessee provided sufficient documentary evidence and AO relied only on employee statements later clarified. Section 68 addition was deleted as transactions were recorded in M/s. Samaira Enterprises' books. Another section 69C addition regarding Nirmali Seeds purchase was properly deleted as no evidence of cash payments existed.

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Issues Involved:
1. Deletion of addition under Section 68 of the Income Tax Act.
2. Deletion of addition under Section 69A of the Income Tax Act.
3. Deletion of addition under Section 69C of the Income Tax Act.

Issue 1: Deletion of Addition under Section 68
The Revenue challenged the deletion of an addition of Rs. 4,63,52,504/- under Section 68 of the Income Tax Act for A.Y. 2021-22. The Assessing Officer (AO) argued that cash sales were unaccounted, based on loose sheets found during a search. The CIT(A) found that the sales were recorded in the books of M/s. Samaira Enterprises, which regularly filed returns and paid taxes. The CIT(A) directed the AO to verify the records of M/s. Samaira Enterprises and deleted the addition in the hands of the appellant. This decision was upheld as the AO failed to prove the sales were unaccounted.

Issue 2: Deletion of Addition under Section 69A
The AO made an addition of Rs. 2,27,19,500/- under Section 69A, treating cash receipts as unexplained money. The CIT(A) found that the sales were recorded in the books of M/s. Samaira Enterprises and the loose sheets were not reliable evidence. The CIT(A) directed the AO to verify the records of M/s. Samaira Enterprises and deleted the addition. This decision was upheld as the AO failed to prove the cash receipts were unexplained.

Issue 3: Deletion of Addition under Section 69C
The AO made an addition of Rs. 4,72,00,000/- under Section 69C, treating purchases as unexplained expenditure. The CIT(A) found that the purchases were supported by invoices, transport documents, and stock records. The CIT(A) deleted the addition as the AO failed to disprove the documentary evidence. This decision was upheld as the AO relied solely on employee statements without corroborating evidence.

Additional Issues:
- Addition of Rs. 11,20,000/- under Section 69C: The AO added this amount based on an email suggesting under-invoicing. The CIT(A) found no evidence of cash payments and deleted the addition.
- Addition of Rs. 13,85,294/- under Section 69A: The AO added this amount based on loose sheets. The CIT(A) directed the AO to verify the records of M/s. Samaira Enterprises and confirmed the addition only where verification was not possible.

Conclusion:
The Revenue's appeals for A.Y. 2019-20, 2020-21, and 2021-22 were dismissed as the CIT(A)'s decisions were based on substantial evidence and proper verification directives. The AO's reliance on uncorroborated statements and loose sheets was insufficient to sustain the additions.

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