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The ITAT set aside multiple additions and assessments upheld under sections 153A, 153C, 69C, 69A, 115BBE, and 251(1) of the Income Tax Act, holding that no incriminating material was found against the assessee during search proceedings relevant to certain years where assessments stood completed. Additions based solely on the DVO's valuation report and unsupported alleged unaccounted sales were quashed. The deemed dividend addition under section 2(22)(e) was deleted, following earlier finality in the assessee's own case. Disallowance of bad debts was reversed due to lack of dispute on genuineness. Purchases treated as bogus were disallowed due to absence of corroborative evidence. Jewellery valuation additions were deleted considering the assessee's status. The tribunal also held that intra-group circular transactions inflated turnover, negating 80IC deductions for such profits. Approval under section 153D was quashed for lack of proper application of mind. Overall, the appeals were allowed substantially in favor of the assessee.
The ITAT set aside multiple additions and assessments upheld under sections 153A, 153C, 69C, 69A, 115BBE, and 251(1) of the Income Tax Act, holding that no incriminating material was found against the assessee during search proceedings relevant to certain years where assessments stood completed. Additions based solely on the DVO's valuation report and unsupported alleged unaccounted sales were quashed. The deemed dividend addition under section 2(22)(e) was deleted, following earlier finality in the assessee's own case. Disallowance of bad debts was reversed due to lack of dispute on genuineness. Purchases treated as bogus were disallowed due to absence of corroborative evidence. Jewellery valuation additions were deleted considering the assessee's status. The tribunal also held that intra-group circular transactions inflated turnover, negating 80IC deductions for such profits. Approval under section 153D was quashed for lack of proper application of mind. Overall, the appeals were allowed substantially in favor of the assessee.
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