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127 cases — 17 Apr 2026
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The Tribunal held that the assessee had provided a comprehensive set of documents, including cash flow statements, SPAs, and bank confirmations, establishing the identity, creditworthiness, and genuineness of the cash transactions. The AO failed to provide contrary evidence and arbitrarily treated similar transactions differently.
The Tribunal noted that the assessee failed to respond to the AO's notices, leading to an ex-parte assessment. While the CIT(A) deleted the addition based on additional evidence, it was observed that this evidence (ATM Service Agreement, bank statements, commission invoices) was not properly verified by the CIT(A) or referred back to the AO, violating Rule 46A of the Income Tax Rules. Therefore, the matter was restored to the AO for fresh examination and verification.
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The Tribunal noted that the assessee, despite maintaining books of accounts, failed to provide necessary details and documentary evidence to the revenue authorities regarding its supplies and receipts. The Tribunal decided to give the assessee an opportunity to present these details.