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2022 (9) TMI 338 - AT - Income TaxUndisclosed income - scrutiny assessment - exact amount as not discernable from the statement of 26AS - mismatch between the receipts shown by the assessee, vis-à-vis. as per 26AS i.e. TDS details - HELD THAT:- The assessee has explained its position that in the statement of 26AS, the amount for which a bill was prepared by the concerned authority would reflect and sometime it is not necessary that advance given by the assessee should match ultimately with the purchases made by it. The advance could be further adjusted for other purchases. This simple thing has not been appreciated by the revenue authorities. Assessing Officer keeps on making the reference of Bank account, partial payments, etc. If he has any doubt, he should ask Tata Metaliks DI Pipes Limited. In that exercise, lot of unnecessary litigation as well as wastage of resources could be avoided. Similar is the situation with regard to other small issues by making reference of irrelevant things the disallowance has been made. The simple way for AO was to cross verify from the concerned party, without adopting that course, he keeps on drawing inference of defects in the details of assessee by way of a deductive reasoning method. On due consideration of the details, we are of the view that the disallowance is not sustainable. We allow the appeal of the assessee and delete the disallowance. Appeal of assessee allowed.
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