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ITAT held that CIT(A) improperly deleted tax addition under Section 68 without providing reasonable opportunity to Assessing Officer (AO) to examine additional evidence. The tribunal found CIT(A) violated procedural requirements by not allowing AO to verify creditworthiness, identity, and transaction genuineness of subscriber companies. Despite assessee procuring subscriber documents, their inability to ensure subscriber presence and circuitous bank transactions raised credibility concerns. ITAT set aside CIT(A)'s order and remanded the matter for fresh consideration, partially allowing revenue's appeal for statistical purposes, emphasizing strict adherence to procedural guidelines in tax assessment proceedings.
ITAT held that CIT(A) improperly deleted tax addition under Section 68 without providing reasonable opportunity to Assessing Officer (AO) to examine additional evidence. The tribunal found CIT(A) violated procedural requirements by not allowing AO to verify creditworthiness, identity, and transaction genuineness of subscriber companies. Despite assessee procuring subscriber documents, their inability to ensure subscriber presence and circuitous bank transactions raised credibility concerns. ITAT set aside CIT(A)'s order and remanded the matter for fresh consideration, partially allowing revenue's appeal for statistical purposes, emphasizing strict adherence to procedural guidelines in tax assessment proceedings.
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