Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT upheld the CIT(A)'s deletion of an addition under s. 69C, finding the AO's treatment legally unsustainable. The AO ignored comprehensive documentary evidence submitted by the assessee - ledger entries, supplier invoices, delivery challans, inventory registers, bank remittances, vehicle entry/exit records, lorry receipts and warehouse log books - and did not dispute their veracity. The tribunal noted the supplier's GST cancellation postdated the challenged purchases, undermining the AO's sham-transaction assertion. Given the assessee's substantiation and the AO's failure to engage with or controvert the evidence, ITAT confirmed that the addition was unjustified and upheld relief granted by the CIT(A).
ITAT upheld the CIT(A)'s deletion of an addition under s. 69C, finding the AO's treatment legally unsustainable. The AO ignored comprehensive documentary evidence submitted by the assessee - ledger entries, supplier invoices, delivery challans, inventory registers, bank remittances, vehicle entry/exit records, lorry receipts and warehouse log books - and did not dispute their veracity. The tribunal noted the supplier's GST cancellation postdated the challenged purchases, undermining the AO's sham-transaction assertion. Given the assessee's substantiation and the AO's failure to engage with or controvert the evidence, ITAT confirmed that the addition was unjustified and upheld relief granted by the CIT(A).
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