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The ITAT allowed the assessee's appeal and directed deletion of contested additions. The Tribunal held that additions under section 69C and for alleged personal use of vehicle were based on mere estimation and documents recovered from mobile devices without independent verification; such ad hoc disallowances in a search assessment lack cogent evidential foundation and cannot be sustained. The ITAT accepted the assessee's explanation and bank records showing third-party payment of travel expenses, and found no inquiry was conducted regarding the jewellery transaction or counter-party statements. Consequently, absent corroborative enquiries or supporting material, all impugned additions were deleted and the assessment revisited accordingly.
The ITAT allowed the assessee's appeal and directed deletion of contested additions. The Tribunal held that additions under section 69C and for alleged personal use of vehicle were based on mere estimation and documents recovered from mobile devices without independent verification; such ad hoc disallowances in a search assessment lack cogent evidential foundation and cannot be sustained. The ITAT accepted the assessee's explanation and bank records showing third-party payment of travel expenses, and found no inquiry was conducted regarding the jewellery transaction or counter-party statements. Consequently, absent corroborative enquiries or supporting material, all impugned additions were deleted and the assessment revisited accordingly.
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