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    <title>2024 (8) TMI 283 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad dismissed revenue&#039;s appeals across multiple assessment years. The tribunal held that additions under Section 153A for fictitious commodity losses were unsustainable due to lack of incriminating material found during search operations. Following Supreme Court precedent in Kelvinator and Gujarat HC in Saumya Construction, reassessments must be based on tangible evidence. The tribunal also deleted additions for unexplained credits under Section 68, noting insufficient verification efforts by authorities despite adequate information provided by assessee. Disallowances under Section 14A were similarly deleted as they pertained to unabated years without supporting incriminating material. Revenue&#039;s appeals dismissed; assessee&#039;s cross-objections allowed.</description>
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    <pubDate>Wed, 31 Jul 2024 00:00:00 +0530</pubDate>
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      <title>2024 (8) TMI 283 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=756579</link>
      <description>ITAT Ahmedabad dismissed revenue&#039;s appeals across multiple assessment years. The tribunal held that additions under Section 153A for fictitious commodity losses were unsustainable due to lack of incriminating material found during search operations. Following Supreme Court precedent in Kelvinator and Gujarat HC in Saumya Construction, reassessments must be based on tangible evidence. The tribunal also deleted additions for unexplained credits under Section 68, noting insufficient verification efforts by authorities despite adequate information provided by assessee. Disallowances under Section 14A were similarly deleted as they pertained to unabated years without supporting incriminating material. Revenue&#039;s appeals dismissed; assessee&#039;s cross-objections allowed.</description>
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      <pubDate>Wed, 31 Jul 2024 00:00:00 +0530</pubDate>
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