ITAT allowed the assessee's appeal and deleted the addition...

ITAT allowed the assessee's appeal and deleted the addition framed under proceedings pursuant to section 144C(5) of the Act. The Tribunal held that the assessee had satisfactorily explained the receipt as a refund of a prior deposit with a third-party company, supported by balance-sheet entries and an audit Form 3CD; Revenue failed to place any contrary material on record to rebut those documents. The Assessing Officer merely questioned the third party's creditworthiness without disputing the identity or genuineness of the transaction, and the DRP's directions reflected non-appreciation of the evidence rather than any substantive infirmity. Consequently, the impugned adjustment was cancelled and the assessment amended in favour of the assessee.

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