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ITAT dismissed Revenue's appeals, upholding CIT(A)'s deletion of addition under Section 69. The Assessing Officer's order was found defective due to lack of substantive evidence, failure to confront key witness statements, and inability to establish direct nexus between seized documents and assessee's transactions. The tribunal noted that neither purchase nor seller parties admitted connection to seized documents, and the assessee demonstrated regular transaction records from ledger accounts. Procedural irregularities in assessment, including non-compliance with Section 145(3) and rejection of books of accounts without proper justification, led to the appellate order's confirmation.
ITAT dismissed Revenue's appeals, upholding CIT(A)'s deletion of addition under Section 69. The Assessing Officer's order was found defective due to lack of substantive evidence, failure to confront key witness statements, and inability to establish direct nexus between seized documents and assessee's transactions. The tribunal noted that neither purchase nor seller parties admitted connection to seized documents, and the assessee demonstrated regular transaction records from ledger accounts. Procedural irregularities in assessment, including non-compliance with Section 145(3) and rejection of books of accounts without proper justification, led to the appellate order's confirmation.
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