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ITAT dismissed Revenue's appeal concerning unexplained money ...


Tax Tribunal Rejects Revenue's Appeal on Unexplained Money, Rules Registered Sale Deed Value Prevails Over Agreement Amounts.

January 25, 2025

Case Laws     Income Tax     AT

ITAT dismissed Revenue's appeal concerning unexplained money under s.69A, rejecting additions based on difference between agreement to sale and final sale deed values. The Tribunal upheld that registered sale deed value prevails over unregistered agreement amounts. Additions under s.69A based on loose papers were deleted as these were deemed "dumb documents" lacking corroborative evidence. Regarding undisclosed cash receipts, ITAT found transactions were properly accounted through partner's capital account. Unexplained expenditure additions under s.69C were deleted as Revenue failed to establish alleged payments. Following precedent, Tribunal held loose sheets/diaries inadmissible as evidence for additions. ITAT emphasized registered sale deeds' sanctity over mere agreements to sale without contrary evidence.

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