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The ITAT upheld the deletion of additions made by the AO relating to unaccounted cash deposits and interest for AY 2012-13, holding that reliance solely on an uncorroborated sworn statement without independent documentary evidence is insufficient to sustain additions under the Income Tax Act. Additions premised on alleged cash deposits and interest payments were quashed for lack of incriminating material and failure to discharge the burden of proof. Similarly, additions based on third-party material concerning unaccounted loans and interest for AY 2015-16 were deleted, as the AO failed to conduct proper inquiries or produce cogent evidence linking the assessee to the loans. Lastly, additions for unexplained cash were also deleted since the assessee's reconciliation was unrefuted and the Revenue did not establish beyond reasonable doubt that the cash was unexplained. The Tribunal affirmed the CIT(A)'s orders deleting all substantive and protective additions, ruling in favor of the assessee.
The ITAT upheld the deletion of additions made by the AO relating to unaccounted cash deposits and interest for AY 2012-13, holding that reliance solely on an uncorroborated sworn statement without independent documentary evidence is insufficient to sustain additions under the Income Tax Act. Additions premised on alleged cash deposits and interest payments were quashed for lack of incriminating material and failure to discharge the burden of proof. Similarly, additions based on third-party material concerning unaccounted loans and interest for AY 2015-16 were deleted, as the AO failed to conduct proper inquiries or produce cogent evidence linking the assessee to the loans. Lastly, additions for unexplained cash were also deleted since the assessee's reconciliation was unrefuted and the Revenue did not establish beyond reasonable doubt that the cash was unexplained. The Tribunal affirmed the CIT(A)'s orders deleting all substantive and protective additions, ruling in favor of the assessee.
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