ITAT dismissed the Revenue's appeal and upheld CIT(A)'s deletion of all additions. The addition under s.68 towards alleged bogus unsecured loans was rejected as the assessee had furnished complete documentary evidence, lenders responded to s.133(6) notices, loans were repaid, creditors had sufficient financial capacity, and no defects were pointed out by AO; reliance on third-party statements without cross-examination was held untenable. The estimated addition on alleged bogus purchases at 0.5% was also deleted, CIT(A) having found, on facts, that AO's inference was erroneous and unsupported by evidence. Further, the addition of notional interest on supposed cash loans was deleted since the loans were through banking channels, duly recorded, with interest paid by bank, and penalty proceedings under ss.271D/271E had been dropped.
ITAT dismissed the Revenue's appeal and upheld CIT(A)'s deletion of all additions. The addition under s.68 towards alleged bogus unsecured loans was rejected as the assessee had furnished complete documentary evidence, lenders responded to s.133(6) notices, loans were repaid, creditors had sufficient financial capacity, and no defects were pointed out by AO; reliance on third-party statements without cross-examination was held untenable. The estimated addition on alleged bogus purchases at 0.5% was also deleted, CIT(A) having found, on facts, that AO's inference was erroneous and unsupported by evidence. Further, the addition of notional interest on supposed cash loans was deleted since the loans were through banking channels, duly recorded, with interest paid by bank, and penalty proceedings under ss.271D/271E had been dropped.
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