2026 (4) TMI 1489

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....t corroborative evidence. 2. The reopening u/s 147 is invalid as it relies solely on third-party search material without independent verification. 3. No evidence exists that the assessee incurred expenditure of Rs. 10,71,600/-, rendering section 69C inapplicable. 4. Violation of natural justice no cross-examination of key persons whose statements were relied upon. 5. AO made no independent inquiry or verification of alleged purchases. 6. Addition u/s 69C and taxation u/s 115BBE are arbitrary and excessive. 7. The appellant reserves the right to amend, alter or withdraw any grounds at hearing." 3. The assessee filed return of income for assessment year 2020-21 on 29-12-2020 declaring i....

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....nt of other parties were also taken during search action. The Assessing Officer further held that the assessee made unaccounted cash purchases of Rs. 10,71,600/- from M/s. Ambika Ashish Tradelink LLP and failed to offer full explanation of all documentary evidences in respect of source of unaccounted cash purchases of Rs. 10,71,600/-. Thus, the Assessing Officer made addition of Rs. 10,71,600/- u/s. 69C read with section 115BBEE as unexplained expenditure. 4. The assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. The ld. A.R. submitted that at the time of furnishing the return of income u/s. 148, the hand written Rozmels were not provided to assessee. In such circumstances, the assessee was no....