Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
The ITAT deleted the addition for unexplained investment/purchases because the Revenue failed to produce material directly linking the assessee to the alleged unaccounted transactions with Tirth Gold. The Tribunal noted that the assessee had furnished ledger accounts, bank statement, GST registration certificate and a declaration from Tirth Gold stating that no sales were made to the assessee for the relevant assessment year, but these documents were overlooked. Reliance only on third-party statements and digital data, without corroboration identifying the assessee as involved in undisclosed purchases or investment, was insufficient to sustain the addition. The assessee's appeal was allowed.
The ITAT deleted the addition for unexplained investment/purchases because the Revenue failed to produce material directly linking the assessee to the alleged unaccounted transactions with Tirth Gold. The Tribunal noted that the assessee had furnished ledger accounts, bank statement, GST registration certificate and a declaration from Tirth Gold stating that no sales were made to the assessee for the relevant assessment year, but these documents were overlooked. Reliance only on third-party statements and digital data, without corroboration identifying the assessee as involved in undisclosed purchases or investment, was insufficient to sustain the addition. The assessee's appeal was allowed.
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