Rosha Alloys P. Ltd. v. Dy. CIT (2025) 127 ITR 76 / 175 taxmann.com 622 (Chd.)(Trib.)

S. 69A: Unexplained money-Unaccounted production-Estimation based on variation in electricity consumption-No evidence of unaccounted purchases or sales-Addition deleted.[S. 132]

The Assessing Officer estimated unaccounted production and sales solely on the basis of higher electricity consumption. The Tribunal held that fluctuations in electricity consumption within a reasonable range could not, by themselves, justify estimation of unaccounted production in the absence of any evidence of purchases or sales outside the books. The addition was deleted. (AY. 2018-19, 2019-20 & 2020-21).

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