Section 69C Addition Deleted as Customs Assessable Value Is Not Proof of Unexplained Expenditure

DCIT Vs Azure Power (Raj) Pvt Ltd (ITAT Delhi) Summary : The Income Tax Appellate Tribunal dismissed the Revenue’s appeal and upheld the deletion of an addition made under Section 69C of the Income Tax Act on account of alleged unexplained expenditure arising from differences between customs assessable value and invoice value of imported goods. The assessee, engaged in solar power generation, had imported modules and cable harnesses for setting up its solar plant and recorded the purchases in its books. The Assessing Officer treated the difference between the Customs Department’s assessabl...