https://www.taxtmi.com/caselaws?id=750957 The ITAT Surat ruled in favor of the assessee on multiple grounds. The tribunal deleted the addition under section 68, holding that statements recorded on oath during survey proceedings under section 133A have no evidential value without corroborative evidence, which the AO failed to provide. The penalty under section 271F was also deleted as the assessee showed sufficient cause for filing a belated return due to business losses. Regarding the assessment under section 144, the tribunal restored the matter to the AO for de novo adjudication, noting that the assessee was denied proper opportunity to be heard due to non-delivery of notices, violating principles of natural justice. en-us Thu, 28 Mar 2024 00:00:00 +0530 Wed, 03 Apr 2024 10:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750957 The ITAT Surat ruled in favor of the assessee on multiple grounds. The tribunal deleted the addition under section 68, holding that statements recorded on oath during survey proceedings under section 133A have no evidential value without corroborative evidence, which the AO failed to provide. The penalty under section 271F was also deleted as the assessee showed sufficient cause for filing a belated return due to business losses. Regarding the assessment under section 144, the tribunal restored the matter to the AO for de novo adjudication, noting that the assessee was denied proper opportunity to be heard due to non-delivery of notices, violating principles of natural justice. Case-Laws Income Tax Thu, 28 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750957