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ITAT dismissed Revenue's appeal and upheld deletion of addition made u/s 69C towards alleged unexplained expenditure on construction of a plant in Mewat, Haryana. It held that the assessee had not commenced business and had generated no revenue, making it improbable that such expenditure was incurred from undisclosed income. The loose papers and WhatsApp chats relied upon by the AO were uncorroborated, with figures not matching any identified party, and no valuation or independent verification was undertaken. ITAT noted that assessment of a related entity was completed without adverse inference. In absence of cogent evidence linking the expenditure to the assessee, the addition was unsustainable.
ITAT dismissed Revenue's appeal and upheld deletion of addition made u/s 69C towards alleged unexplained expenditure on construction of a plant in Mewat, Haryana. It held that the assessee had not commenced business and had generated no revenue, making it improbable that such expenditure was incurred from undisclosed income. The loose papers and WhatsApp chats relied upon by the AO were uncorroborated, with figures not matching any identified party, and no valuation or independent verification was undertaken. ITAT noted that assessment of a related entity was completed without adverse inference. In absence of cogent evidence linking the expenditure to the assessee, the addition was unsustainable.
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