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ITAT allowed the appeal and deleted the additions. The Tribunal held there was no cogent evidence of remission or cessation of liability under s.41(1), noting commission entries were not actually paid and books corroborated that position; PANs and account particulars of third parties were produced and mere non-response to s.133(6) notices did not justify additions absent verification by the respective AOs. The cash-deposit addition was also rejected: bank statements, cash book and earlier financials established the deposits derived from withdrawals and disposal of prior-business assets, and the AO failed to examine these records. Both disputed additions were therefore deleted and grounds allowed in favour of the assessee.
ITAT allowed the appeal and deleted the additions. The Tribunal held there was no cogent evidence of remission or cessation of liability under s.41(1), noting commission entries were not actually paid and books corroborated that position; PANs and account particulars of third parties were produced and mere non-response to s.133(6) notices did not justify additions absent verification by the respective AOs. The cash-deposit addition was also rejected: bank statements, cash book and earlier financials established the deposits derived from withdrawals and disposal of prior-business assets, and the AO failed to examine these records. Both disputed additions were therefore deleted and grounds allowed in favour of the assessee.
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