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The ITAT upheld the principle of consistency, affirming that the assessee's income declared under presumptive taxation u/s 44AD must be accepted as in prior years. The assessee, engaged in wholesale livestock trading and mutton sales, provided valid certification and evidence confirming the business's legitimacy. Previous assessments under section 153A r.w.s. 143(3) consistently accepted the returns filed on a presumptive basis without material change in facts. The Tribunal held that proof of an eligible business existed, and absence of detailed invoices was excused due to the nature of the livestock trade in J&K. The seized cash of Rs. 7 lakhs was satisfactorily explained as part of the assessee's normal business cash flow. Consequently, the addition u/s 69A was disallowed, and the appeal was allowed in favor of the assessee.
The ITAT upheld the principle of consistency, affirming that the assessee's income declared under presumptive taxation u/s 44AD must be accepted as in prior years. The assessee, engaged in wholesale livestock trading and mutton sales, provided valid certification and evidence confirming the business's legitimacy. Previous assessments under section 153A r.w.s. 143(3) consistently accepted the returns filed on a presumptive basis without material change in facts. The Tribunal held that proof of an eligible business existed, and absence of detailed invoices was excused due to the nature of the livestock trade in J&K. The seized cash of Rs. 7 lakhs was satisfactorily explained as part of the assessee's normal business cash flow. Consequently, the addition u/s 69A was disallowed, and the appeal was allowed in favor of the assessee.
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