AO’s Suspicion Not Evidence: Section 68 not Apply to Opening Balances

Raj Kumar Daga HUF Vs ACIT (ITAT Delhi) AO’s Suspicion Not Evidence- Commission Payments Genuine- Section 68 Cannot Apply to Opening Balances Assessee, proprietor of M/s Gappu Ispat, engaged in trading of iron & steel, filed returns declaring income of Rs.31,20,070 for AY 2013-14. In scrutiny, AO disallowed Rs.49,51,599 out of total commission of Rs.1,25,90,385 alleging bogus payments—seven parties did not appear, notices returned unserved, & explanations of three parties were rejected. AO assessed income at Rs.80,71,670. Ld. CIT(A)/NFAC confirmed the additions. Before Tribunal, As...