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The ITAT dismissed the Revenue's appeal, holding that additions under s. 69C were unwarranted. The AO had accepted the assessee's sales of bulls to slaughterhouses but disallowed the cash payments claimed as purchases, thereby treating Rs. 8.89 crore of cash withdrawals as unexplained expenditure. The Tribunal found this approach inconsistent: acceptance of sales logically required acceptance of corresponding purchase outlays necessary to carry on the admitted trading business. The AO could have negated both legs as sham, but did not; rejecting only purchases lacked evidentiary basis. Consequently, the CIT(A)'s deletion of the s. 69C addition was affirmed and the Revenue's appeal dismissed.
The ITAT dismissed the Revenue's appeal, holding that additions under s. 69C were unwarranted. The AO had accepted the assessee's sales of bulls to slaughterhouses but disallowed the cash payments claimed as purchases, thereby treating Rs. 8.89 crore of cash withdrawals as unexplained expenditure. The Tribunal found this approach inconsistent: acceptance of sales logically required acceptance of corresponding purchase outlays necessary to carry on the admitted trading business. The AO could have negated both legs as sham, but did not; rejecting only purchases lacked evidentiary basis. Consequently, the CIT(A)'s deletion of the s. 69C addition was affirmed and the Revenue's appeal dismissed.
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