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ITAT remanded the assessment proceedings, setting aside CIT(A)'s order for all four tax years. The appellate tribunal found insufficient evidentiary basis for income addition under Section 69A and directed the Assessing Officer (AO) to conduct a fresh examination. The AO must provide substantive materials forming the basis of income addition, afford the assessee a hearing, and make a legally appropriate determination after comprehensive review and cooperation from the assessee.
ITAT remanded the assessment proceedings, setting aside CIT(A)'s order for all four tax years. The appellate tribunal found insufficient evidentiary basis for income addition under Section 69A and directed the Assessing Officer (AO) to conduct a fresh examination. The AO must provide substantive materials forming the basis of income addition, afford the assessee a hearing, and make a legally appropriate determination after comprehensive review and cooperation from the assessee.
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