In the result, the appeal filed by the assessee is allowed
Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay
145(3) of the Act, no valid addition can be made. The Authorities Below have however ignored this vital fact while dismissing the appeal and confirming the addition of Rs.50,90,194/- on the basis of misconceived presumptions and surmises that the sale proceeds of the Vehicles as shown in the Audited Books were a 'Colorable Device', relying heavily