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ITAT affirmed the CIT(A)'s order, disallowing the revenue's additions made under s. 69C alleging unaccounted capital investment and sales in relation to 35 group shops. The Tribunal held that the only materials relied upon-loose papers seized during search and a retracted statement recorded u/s 132(4)-were undated, unsigned and lacked any independent corroborative evidence linking them to tax evasion or specific capital investment by the assessee. In absence of direct nexus or incriminating material corroborating the alleged undisclosed transactions, the additions could not be sustained. The relief granted to the assessee by the CIT(A) is upheld and the revenue's grounds of appeal are dismissed.
ITAT affirmed the CIT(A)'s order, disallowing the revenue's additions made under s. 69C alleging unaccounted capital investment and sales in relation to 35 group shops. The Tribunal held that the only materials relied upon-loose papers seized during search and a retracted statement recorded u/s 132(4)-were undated, unsigned and lacked any independent corroborative evidence linking them to tax evasion or specific capital investment by the assessee. In absence of direct nexus or incriminating material corroborating the alleged undisclosed transactions, the additions could not be sustained. The relief granted to the assessee by the CIT(A) is upheld and the revenue's grounds of appeal are dismissed.
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