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ITAT dismissed revenue's appeal regarding unexplained credits u/s 68, holding that seized materials belonged to Rama Group entities based on Panchnama records, not the assessee, and additions cannot be made against third parties without proper linkage. For cash transactions, ITAT upheld CIT(A)'s deletion after AO accepted unreconciled amount of Rs. 42.79 lakhs and assessee surrendered Rs. 52.50 lakhs. Book balance addition was restricted to Rs. 6.35 lakhs excluding opening balance. Sales addition was rejected as assessee being director is separate from company without corporate veil lifting. Jewellery addition was deleted based on affidavits proving ownership by in-laws. Cattle feed trading matter remanded to CIT(A) for fresh adjudication with proper hearing opportunity.
ITAT dismissed revenue's appeal regarding unexplained credits u/s 68, holding that seized materials belonged to Rama Group entities based on Panchnama records, not the assessee, and additions cannot be made against third parties without proper linkage. For cash transactions, ITAT upheld CIT(A)'s deletion after AO accepted unreconciled amount of Rs. 42.79 lakhs and assessee surrendered Rs. 52.50 lakhs. Book balance addition was restricted to Rs. 6.35 lakhs excluding opening balance. Sales addition was rejected as assessee being director is separate from company without corporate veil lifting. Jewellery addition was deleted based on affidavits proving ownership by in-laws. Cattle feed trading matter remanded to CIT(A) for fresh adjudication with proper hearing opportunity.
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