Purchases Attributed to Other Entities: ITAT Deletes ₹3 Crore Addition Citing AO’s Acceptance of Facts in Remand Report

The Income Tax Appellate Tribunal (ITAT) deleted a ₹3 crore addition made by the Assessing Officer (AO) on alleged bogus purchases, noting that the AO had already accepted the genuineness of transactions in the remand report. The tribunal observed that sustaining such additions would amount to double jeopardy and arbitrary taxation. The order reaffirms that appellate authorities must consider all evidentiary records and departmental submissions holistically. It strengthens taxpayer rights against inconsistent departmental practices and ensures accountability in assessment proceedings. The decision upholds the principle of judicial consistency in income tax administration.