The ITAT upheld the validity of the notice issued under section 148 by the jurisdictional AO, dismissing the assessee's challenge regarding issuance by the faceless AO. The defect in sanction under section 151 without a valid DIN was held irregular but not illegal, and the notice bearing a valid DIN was sustained. Disallowance of bogus purchases was confirmed at 12.5%. Additions under section 69C for unexplained expenditure based on diary entries were upheld, while protective additions under section 69A related to seized diary entries and unexplained gold investment were deleted, as the AO failed to prove cash purchases or excess gold. The addition of long-term capital gains on sale of property was partly allowed with directions to recompute tax excluding section 69A applicability. Overall, the appeal was partly allowed, with the protective additions deleted and substantive additions sustained where adequately supported by evidence.
The ITAT upheld the validity of the notice issued under section 148 by the jurisdictional AO, dismissing the assessee's challenge regarding issuance by the faceless AO. The defect in sanction under section 151 without a valid DIN was held irregular but not illegal, and the notice bearing a valid DIN was sustained. Disallowance of bogus purchases was confirmed at 12.5%. Additions under section 69C for unexplained expenditure based on diary entries were upheld, while protective additions under section 69A related to seized diary entries and unexplained gold investment were deleted, as the AO failed to prove cash purchases or excess gold. The addition of long-term capital gains on sale of property was partly allowed with directions to recompute tax excluding section 69A applicability. Overall, the appeal was partly allowed, with the protective additions deleted and substantive additions sustained where adequately supported by evidence.
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