https://www.taxtmi.com/caselaws?id=778451 ITAT DELHI - AT set aside additions and enhancements upheld by the AO/CIT(A), directing reversal of impugned additions. The tribunal found seized diary entries partly related to a third-party project, and absent independent corroboration or statements identifying the assessee, additions based on suspicion could not stand. Revenue's enhancement under the Percentage of Completion Method was quashed because PoCM workings were not controverted by AO, were consistent across years, and no reasonable basis or opportunity was shown for departing from prior treatment. Enhancements premised on alleged statements under s.132(4) were also invalidated for lack of corroboration and failure to issue show-cause/oppportunity. en-us Fri, 17 Jan 2025 00:00:00 +0530 Mon, 15 Sep 2025 16:53:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778451 ITAT DELHI - AT set aside additions and enhancements upheld by the AO/CIT(A), directing reversal of impugned additions. The tribunal found seized diary entries partly related to a third-party project, and absent independent corroboration or statements identifying the assessee, additions based on suspicion could not stand. Revenue's enhancement under the Percentage of Completion Method was quashed because PoCM workings were not controverted by AO, were consistent across years, and no reasonable basis or opportunity was shown for departing from prior treatment. Enhancements premised on alleged statements under s.132(4) were also invalidated for lack of corroboration and failure to issue show-cause/oppportunity. Case-Laws Income Tax Fri, 17 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778451