Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT deleted additions under s.69B for alleged cash payment for old machinery purchase, finding the printout was not a "speaking document" that could sustain charges without corroborative evidence. The tribunal noted M/s Chetak Enterprises denied receiving cash, and the machinery's market value aligned with the valuation report. Similarly, additions under s.69C for alleged cash payments to suppliers were deleted as there was no admission of cash transactions from either the appellant or recipients, with evidence showing payments were made through banking channels. The ITAT criticized the AO for failing to gather corroborative evidence or allowing cross-examination of the alleged recipients, concluding there was no justification for sustaining either addition.
ITAT deleted additions under s.69B for alleged cash payment for old machinery purchase, finding the printout was not a "speaking document" that could sustain charges without corroborative evidence. The tribunal noted M/s Chetak Enterprises denied receiving cash, and the machinery's market value aligned with the valuation report. Similarly, additions under s.69C for alleged cash payments to suppliers were deleted as there was no admission of cash transactions from either the appellant or recipients, with evidence showing payments were made through banking channels. The ITAT criticized the AO for failing to gather corroborative evidence or allowing cross-examination of the alleged recipients, concluding there was no justification for sustaining either addition.
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