Validity of proceedings u/s 153C - The Tribunal upheld the ...

Case Laws     Income Tax

April 8, 2024

Validity of proceedings u/s 153C - The Tribunal upheld the proceedings u/s 153C, agreeing with the CIT(A)'s decision that the material seized during the search had a bearing on the determination of the assessee's total income, thereby justifying the assumption of jurisdiction u/s 153C. - The Tribunal concurred with the CIT(A) that the seized documents and the statements, especially when retracted, could not be solely relied upon to make additions to the assessee's income. It was emphasized that corroborative evidence was necessary to attribute the entries in the seized materials to the assessee. - The Tribunal agreed with the CIT(A)'s deletion of these additions, finding no direct reference to the assessee in the seized materials and considering the statements unreliable without independent corroborative evidence.

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