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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.
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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