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ITAT upheld CIT(A)'s deletion of disallowance under section 69C regarding "Downside on Sale of Flats" expenses totaling INR 17.60 crores. The assessee entered underwriting agreements with developer BDMC for specified flats, assuming all risks and rewards from MOU execution. When BDMC sold 20 flats to end customers at prices lower than assessee's contractual payment obligations to BDMC, genuine business losses resulted. ITAT distinguished this arrangement from actual property sales, finding consistent treatment across assessment years where similar arrangements generated taxable income. The tribunal rejected revenue's contention regarding inadequate documentation, noting comprehensive evidence including MOUs, bank statements, and ledger accounts establishing transaction genuineness. ITAT also dismissed section 68 addition concerning unsecured loans, finding AO's rejection based solely on IDBI Bank's non-response to notices under section 133(6) insufficient given adequate documentary evidence provided by assessee.
ITAT upheld CIT(A)'s deletion of disallowance under section 69C regarding "Downside on Sale of Flats" expenses totaling INR 17.60 crores. The assessee entered underwriting agreements with developer BDMC for specified flats, assuming all risks and rewards from MOU execution. When BDMC sold 20 flats to end customers at prices lower than assessee's contractual payment obligations to BDMC, genuine business losses resulted. ITAT distinguished this arrangement from actual property sales, finding consistent treatment across assessment years where similar arrangements generated taxable income. The tribunal rejected revenue's contention regarding inadequate documentation, noting comprehensive evidence including MOUs, bank statements, and ledger accounts establishing transaction genuineness. ITAT also dismissed section 68 addition concerning unsecured loans, finding AO's rejection based solely on IDBI Bank's non-response to notices under section 133(6) insufficient given adequate documentary evidence provided by assessee.
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