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ITAT affirmed deletion of additions against the assessee, holding that the limbs of s.69A were not satisfied where no cash, bullion, jewellery or other incriminating assets were found and no reliable money trail linked the impounded booking forms to undisclosed receipts. Additions under s.69C based on differences between estimated booking values and sale deed consideration were also deleted where there was no evidence of genuine customer bookings and no corroboration of on-money receipts. The Tribunal found the AO failed to produce corroborative evidence or properly examine customers, and relied on loose papers and electronic material without requisite evidentiary foundation, thereby deciding against the revenue.
ITAT affirmed deletion of additions against the assessee, holding that the limbs of s.69A were not satisfied where no cash, bullion, jewellery or other incriminating assets were found and no reliable money trail linked the impounded booking forms to undisclosed receipts. Additions under s.69C based on differences between estimated booking values and sale deed consideration were also deleted where there was no evidence of genuine customer bookings and no corroboration of on-money receipts. The Tribunal found the AO failed to produce corroborative evidence or properly examine customers, and relied on loose papers and electronic material without requisite evidentiary foundation, thereby deciding against the revenue.
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