Incriminating documents seized during search proceedings, like ...

Incriminating docs like satakhat & digital data insufficient for additions u/ss 69A & 69B. Lack of payment proof, unexamined sellers, no probe.

Case Laws     Income Tax

August 10, 2024

Incriminating documents seized during search proceedings, like notarized satakhat and digital data, were the basis for additions u/ss 69A and 69B. However, the CIT(A) deleted the additions. The Tribunal upheld the CIT(A)'s order, observing that the satakhat lacked acknowledgment of payment, the sellers were not examined, and no independent investigation was conducted. Regarding the digital data, no evidence of on-money payment for land purchase was found. The assessee's father had filed a settlement application, offering income on the transaction amount, which was accepted. The Tribunal held that in the absence of corroborative evidence of on-money payment, the CIT(A)'s deletion of additions was justified.

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