Additions based on BUP IDs, internal identifiers and presumptive opening deposits are not sustainable

DCIT Vs Anil Dhirajlal Ambani (ITAT Mumbai) ITAT Mumbai held that additions made on substantive and protective basis merely on the strength of BUP IDs, internal identifiers, and presumptive opening deposits are unsustainable. Accordingly, appeal of revenue dismissed. Facts- The assessee filed the return of income declaring a total income of Rs.7,11,89,070/-, which was processed u/s. 143(1) of the Act. Subsequently, reasons were recorded and notice u/s. 148 was issued. The assessment was thereafter completed u/s. 147 r.w.s. 143(3) of the Act. AO, relying upon the report of the Addl. DGIT (Inve...