Additions Under Section 153C Invalid Without Corroborative Evidence Beyond "Hazir Johri" Software Entries

The ITAT ruled in favor of the assessee regarding additions made under section 153C based on entries in "Hazir Johri" software discovered during a search of JBL. While the AO relied on a director's statement confirming the software documented both official and unofficial transactions, the Tribunal found no concrete evidence linking the assessee to transactions in the combined ledger. The revenue failed to produce corroborative evidence such as bills, vouchers, or stock registers to establish the nature of transactions or prove cash sales belonged to the assessee. Following precedents in Anoop Kumar Soni and Surender Kumar Jain cases involving similar JBL search matters, the Tribunal concluded that entries in the software alone were insufficient for making additions. .....

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