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ITAT ruled against Revenue's addition under s153A for alleged bogus purchases. Assessment was based solely on pre-search statements from ML and DK without supporting incriminating materials discovered during search operations. Assessee provided complete quantitative details backed by tax audit reports, with no discrepancies except statements and STRs from Investigation Wing. Tribunal emphasized that circumstantial evidence and statements alone cannot constitute incriminating material without corroborative proof. Mere reliance on statements recorded prior to search, without additional evidence gathered during search proceedings, failed to establish bogus purchases. Assessment order quashed due to lack of incriminating material found during search.
ITAT ruled against Revenue's addition under s153A for alleged bogus purchases. Assessment was based solely on pre-search statements from ML and DK without supporting incriminating materials discovered during search operations. Assessee provided complete quantitative details backed by tax audit reports, with no discrepancies except statements and STRs from Investigation Wing. Tribunal emphasized that circumstantial evidence and statements alone cannot constitute incriminating material without corroborative proof. Mere reliance on statements recorded prior to search, without additional evidence gathered during search proceedings, failed to establish bogus purchases. Assessment order quashed due to lack of incriminating material found during search.
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