Appeal partly allowed: wildlife eco-adventure tours not tour operator; accommodations not renting; training taxable; penalties and extended limitation...
ITAT held that the assessing officer's additions disallowing purchases were unsustainable and deleted the impugned additions. The Tribunal found the AO had accepted sales, had not rejected the books of account, and had recorded evidence of payment by account-payee cheques and stock reconciliation statements; the AO produced no evidence of cash being returned to the taxpayer nor conducted any independent verification. Reliance solely on observations of the sales tax department, without independent inquiry, rendered the additions arbitrary. Accordingly, the appeal of the taxpayer was allowed and the assessment adjustments were set aside.
ITAT held that the assessing officer's additions disallowing purchases were unsustainable and deleted the impugned additions. The Tribunal found the AO had accepted sales, had not rejected the books of account, and had recorded evidence of payment by account-payee cheques and stock reconciliation statements; the AO produced no evidence of cash being returned to the taxpayer nor conducted any independent verification. Reliance solely on observations of the sales tax department, without independent inquiry, rendered the additions arbitrary. Accordingly, the appeal of the taxpayer was allowed and the assessment adjustments were set aside.
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