ITAT Mumbai: Section 68 Additions Collapse – No “Source of Source” for Firms, Evidence Overrides Suspicion

DCIT Vs P Vijaykumar & CO (ITAT Mumbai) In this detailed ruling arising from a search assessment under Section 153A, the ITAT Mumbai upheld the deletion of multiple additions made under Sections 68 and 69A, primarily on account of cash deposits, capital introduced by partners, and unsecured loans. The Assessing Officer had framed ex-parte best judgment assessments due to non-compliance and treated various credits as unexplained. However, during appellate proceedings, the assessee furnished comprehensive documentary evidence, which was also examined in remand proceedings. On the issue of ca...