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ITAT held that the bank account credits belonging to employees cannot be attributed to the assessee. The tribunal found a plausible explanation demonstrating that salary accounts were legitimately opened in employees' names, with actual employees present and verifiable during post-search proceedings. The employees' bank accounts were conclusively determined to be owned exclusively by the individual employees, not the corporate entity. Consequently, Section 69A provisions were deemed inapplicable, and the assessee was not required to explain the bank account credits. The tribunal allowed the assessee's grounds, effectively rejecting the revenue's claim of undisclosed income.
ITAT held that the bank account credits belonging to employees cannot be attributed to the assessee. The tribunal found a plausible explanation demonstrating that salary accounts were legitimately opened in employees' names, with actual employees present and verifiable during post-search proceedings. The employees' bank accounts were conclusively determined to be owned exclusively by the individual employees, not the corporate entity. Consequently, Section 69A provisions were deemed inapplicable, and the assessee was not required to explain the bank account credits. The tribunal allowed the assessee's grounds, effectively rejecting the revenue's claim of undisclosed income.
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