No addition u/s 69A without corroborative evidence & cross-examination

ITO Vs K. Mart (ITAT Ahmedabad)

Conclusion: Additions under Section 69A could not be sustained without concrete evidence and due process and AO had not brought any tangible evidence to prove the alleged cash loan.

Held: Revenue had challenged CIT(A)’s decision to delete the addition, which was made based on information from a survey conducted on Pravin S. Shah, proprietor of Manibhadra, who was allegedly involved in providing cash loans through hundis. AO had reopened the assessment under Section 147 and passed an ex-parte order under Sec

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