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The ITAT rejected the revenue's appeal, finding that the Assessing Officer (AO) improperly made additions under sections 69A and 69C without substantive evidence. The tribunal held that the AO relied on uncorroborated documents, specifically a WhatsApp image from an employee's smartphone, which could not be considered credible proof. No physical money was found, and the statements used were retracted. The tribunal emphasized that abstract documents without supporting evidence cannot form the basis for tax additions. Consequently, the additions made by the AO were deleted, and the CIT(A)'s original order was upheld, effectively dismissing the revenue's challenge.
The ITAT rejected the revenue's appeal, finding that the Assessing Officer (AO) improperly made additions under sections 69A and 69C without substantive evidence. The tribunal held that the AO relied on uncorroborated documents, specifically a WhatsApp image from an employee's smartphone, which could not be considered credible proof. No physical money was found, and the statements used were retracted. The tribunal emphasized that abstract documents without supporting evidence cannot form the basis for tax additions. Consequently, the additions made by the AO were deleted, and the CIT(A)'s original order was upheld, effectively dismissing the revenue's challenge.
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