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ITAT reversed AO's additions under s.68 for unexplained bank deposits, finding that while deposits were added as unexplained income, corresponding withdrawals from the same account were not considered in assessment. The tribunal held that additions were unsustainable given the pattern of deposits and withdrawals evidenced in bank statements. Additionally, penalty of Rs.10,000 imposed under s.271(1)(b) for non-appearance was deleted, as AO had provided unreasonably short notice period of one day for appearance. Both issues decided in favor of appellant, with tribunal emphasizing need to consider complete banking transaction patterns and provide reasonable compliance timeframes.
ITAT reversed AO's additions under s.68 for unexplained bank deposits, finding that while deposits were added as unexplained income, corresponding withdrawals from the same account were not considered in assessment. The tribunal held that additions were unsustainable given the pattern of deposits and withdrawals evidenced in bank statements. Additionally, penalty of Rs.10,000 imposed under s.271(1)(b) for non-appearance was deleted, as AO had provided unreasonably short notice period of one day for appearance. Both issues decided in favor of appellant, with tribunal emphasizing need to consider complete banking transaction patterns and provide reasonable compliance timeframes.
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