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of The ITAT upheld the CIT(A)'s deletion of additions relating to alleged bogus packaging and subcontracting expenses, finding the issue to be factual and dependent on evidence furnished by the assessee. The AO's disallowance lacked valid reasons and contrary evidence to disprove the genuineness of subcontractors. The tribunal rejected reliance on missing labor registers and other documentation as insufficient to negate the assessee's claim. Similarly, additions under section 69C for alleged out-of-book purchases based on input-output ratio comparisons were quashed, as the AO's conclusions were speculative and unsupported by credible evidence. The comparison with another entity was deemed irrelevant due to differing product lines. The ITAT found the CIT(A)'s findings to be based on cogent evidence and proper appreciation of facts and accordingly dismissed the revenue's appeal.
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