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Assessment u/s 153A - Addition made on account of over invoicing in purchases - protective addition - The Tribunal meticulously examined the evidence and submissions presented by both parties. It found the statements obtained during the search to be unreliable, lacking corroborative evidence and contradicted by subsequent actions of the assessee. Additionally, the Tribunal criticized the comparison of purchase prices undertaken by the AO, highlighting its flawed nature and absence of legal authority. Ultimately, the Tribunal concluded that the addition made by the AO on account of alleged over-invoicing was unsustainable. It directed the AO to delete the addition across all assessment years.
Assessment u/s 153A - Addition made on account of over invoicing in purchases - protective addition - The Tribunal meticulously examined the evidence and submissions presented by both parties. It found the statements obtained during the search to be unreliable, lacking corroborative evidence and contradicted by subsequent actions of the assessee. Additionally, the Tribunal criticized the comparison of purchase prices undertaken by the AO, highlighting its flawed nature and absence of legal authority. Ultimately, the Tribunal concluded that the addition made by the AO on account of alleged over-invoicing was unsustainable. It directed the AO to delete the addition across all assessment years.
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