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ITAT deleted the addition under s.69A and allowed the taxpayer's grounds, holding that the hypothecation of livestock was immaterial once the loan was repaid and could not sustain a presumption of unexplained income. The Tribunal accepted the taxpayer's evidence of livestock sales - including purchaser confirmations with identity documents - and found the Revenue failed to undertake any independent enquiry or produce material impugning purchasers' creditworthiness. Having accepted the taxpayer's net cash flow and that cash deposited during the demonetisation period derived from livestock sales, the Tribunal reversed the CIT(A)'s balance addition and directed deletion of the impugned s.69A assessment.
ITAT deleted the addition under s.69A and allowed the taxpayer's grounds, holding that the hypothecation of livestock was immaterial once the loan was repaid and could not sustain a presumption of unexplained income. The Tribunal accepted the taxpayer's evidence of livestock sales - including purchaser confirmations with identity documents - and found the Revenue failed to undertake any independent enquiry or produce material impugning purchasers' creditworthiness. Having accepted the taxpayer's net cash flow and that cash deposited during the demonetisation period derived from livestock sales, the Tribunal reversed the CIT(A)'s balance addition and directed deletion of the impugned s.69A assessment.
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