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ITAT allowed the appeal, setting aside the CIT(A)'s order and deleting additions under Section 69. The tribunal found critical procedural and evidentiary defects in the assessment order, specifically noting that the Assessing Officer (AO) relied solely on an incomplete statement without seeking explanations from directors, failed to establish concrete evidence of unaccounted investments, and improperly concluded deposits were made by directors based on minor clerical errors in forms. The tribunal emphasized that the burden of proof lies with the revenue authority, which failed to substantiate allegations of undisclosed investments made by the assessee. The order was decided in favor of the assessee, effectively quashing the disputed tax additions.
ITAT allowed the appeal, setting aside the CIT(A)'s order and deleting additions under Section 69. The tribunal found critical procedural and evidentiary defects in the assessment order, specifically noting that the Assessing Officer (AO) relied solely on an incomplete statement without seeking explanations from directors, failed to establish concrete evidence of unaccounted investments, and improperly concluded deposits were made by directors based on minor clerical errors in forms. The tribunal emphasized that the burden of proof lies with the revenue authority, which failed to substantiate allegations of undisclosed investments made by the assessee. The order was decided in favor of the assessee, effectively quashing the disputed tax additions.
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