CIT(A) Deletes Additions u/s 68; ITAT Upholds Decision, Citing Admissible Evidence u/r 46(4.

CIT(A) did not violate Rule 46A by admitting evidence not produced before AO, as Rule 46(4) permits Appellate Authority to call for evidence. CIT(A) rightly deleted addition of Rs. 60 lakh unsecured loan from mother u/s 68, after examining relevant material. CIT(A) correctly deleted addition of sundry creditors u/s 68, as most were paid in subsequent years and formed part of business transactions. No addition tenable u/s 41(1) for sundry creditors. CIT(A) rightly restricted income estimation to 6% of turnover. Revenue's appeal dismissed by ITAT. .....

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