Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT holds that the approving authority's mechanical approval under section 153D does not preclude substantive consideration; on facts the assessee's revised return declaring 14-15% profit is accepted because group net profit computed from seized and books material is 1.47%, substantially below declared rates and prior-year margins, hence no further addition warranted and impugned additions are deleted, allowing the assessee's cross-objection and dismissing the revenue's appeal. The CIT(A)'s rejection of AO's unsupported agricultural income estimate is upheld on documentary proof (J-forms, khasra/khatauni). Unsecured loans are treated as genuine under section 68 on furnished confirmations, PANs and ITRs; related additions are deleted and revenue's grounds dismissed.
ITAT holds that the approving authority's mechanical approval under section 153D does not preclude substantive consideration; on facts the assessee's revised return declaring 14-15% profit is accepted because group net profit computed from seized and books material is 1.47%, substantially below declared rates and prior-year margins, hence no further addition warranted and impugned additions are deleted, allowing the assessee's cross-objection and dismissing the revenue's appeal. The CIT(A)'s rejection of AO's unsupported agricultural income estimate is upheld on documentary proof (J-forms, khasra/khatauni). Unsecured loans are treated as genuine under section 68 on furnished confirmations, PANs and ITRs; related additions are deleted and revenue's grounds dismissed.
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