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The ITAT allowed the appeal, holding that additions under section 68 could not be sustained where the assessee's cash bank deposits were supported by recorded cash sales in audited books which the AO had not disputed. The Tribunal found the AO's partial acceptance and partial rejection of the same evidentiary material to be based on surmise and conjecture, resulting in double taxation since sales already reflected in income were again treated as unexplained credits. The records, including stock and purchase accounts, were not impugned by Revenue and the cash receipts-occurring pre-demonetization during festival period-were held to emanate from genuine business sales, thus disallowing the section 68 addition.
The ITAT allowed the appeal, holding that additions under section 68 could not be sustained where the assessee's cash bank deposits were supported by recorded cash sales in audited books which the AO had not disputed. The Tribunal found the AO's partial acceptance and partial rejection of the same evidentiary material to be based on surmise and conjecture, resulting in double taxation since sales already reflected in income were again treated as unexplained credits. The records, including stock and purchase accounts, were not impugned by Revenue and the cash receipts-occurring pre-demonetization during festival period-were held to emanate from genuine business sales, thus disallowing the section 68 addition.
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