ITAT allowed the appeal of the assessee and deleted all...

ITAT allowed the appeal of the assessee and deleted all additions made by the AO under sections 68/69 of the Act. The Tribunal held that the AO's tax-sample study and average cash-realisation approach were insufficient to treat deposits and sundry-debtor receipts as unexplained, particularly where audited books and the audit report-neither rejected nor doubted under section 145(3)-reflected corresponding sales and purchases. The AO's failure to make requisite enquiries into purchases, sales or stock undermined the additions. The ITAT agreed that non-response by nine debtors could only justify further investigation, not immediate disallowance, and consequently set aside the entire addition, allowing the assessee's appeal.

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