The ITAT dismissed the Revenue's appeals and allowed the...

The ITAT dismissed the Revenue's appeals and allowed the assessee's appeals. It upheld the CIT(A)'s deletion of additions u/s. 68 in respect of unexplained credits, finding the entity was not a shell and there was no incriminating evidence to sustain the addition. With regard to assessment proceedings u/s. 153A and the addition of GP on alleged unaccounted sales, the Tribunal held extrapolation-based estimates unsustainable where no incriminating material supported suppression for the relevant year; accordingly the GP additions were disallowed. The Tribunal noted incriminating evidence existed for AYs 2020-21 and 2021-22 but not for the impugned assessment, resulting in relief to the assessee.