Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
ITAT ruled that the appellant failed to substantiate the genuineness of purchase transactions involving shell companies. Despite presenting bank statements and tax challans, the tribunal found the documentary evidence insufficient to prove legitimate business transactions. The AO's findings of non-existent suppliers and lack of cross-examination were upheld. Consequently, the tribunal allowed a 12.5% disallowance of unverified purchase amounts, effectively rejecting the appellant's appeal grounds and maintaining the original assessment order's core findings regarding tax evasion through grey market purchases.
ITAT ruled that the appellant failed to substantiate the genuineness of purchase transactions involving shell companies. Despite presenting bank statements and tax challans, the tribunal found the documentary evidence insufficient to prove legitimate business transactions. The AO's findings of non-existent suppliers and lack of cross-examination were upheld. Consequently, the tribunal allowed a 12.5% disallowance of unverified purchase amounts, effectively rejecting the appellant's appeal grounds and maintaining the original assessment order's core findings regarding tax evasion through grey market purchases.
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