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        <h1>Tribunal Upholds Section 153C; Dismisses Revenue Appeals for Lack of Corroboration</h1> <h3>Shri Abhalbhai Arjanbhai Jadeja Versus DCIT, CC</h3> Shri Abhalbhai Arjanbhai Jadeja Versus DCIT, CC - TMI Issues Involved:1. Validity of invoking provisions of section 153C.2. Deletion of additions by CIT(A) for assessment years 2003-04, 2004-05, and 2005-06.Issue-wise Detailed Analysis:1. Validity of invoking provisions of section 153C:The assessee contested the invocation of section 153C, arguing that the document in question, an agreement dated 21.10.2002, did not belong to him. The document was seized during a search on 09.02.2005. The assessee relied on the judgment of the Hon'ble Gujarat High Court in Vijaybhai N. Chandrani Vs ACIT, which stated that documents not belonging to the assessee could not justify invoking section 153C. However, the Tribunal found that the agreement was signed by the assessee and notarized, indicating that it did belong to him. Thus, the Tribunal rejected the assessee's objection, stating that the document was indeed belonging to the assessee and the provisions of section 153C were rightly invoked.2. Deletion of additions by CIT(A) for assessment years 2003-04, 2004-05, and 2005-06:Assessment Year 2003-04:The revenue appealed against the deletion of an addition of Rs. 15 lakhs by CIT(A), which was considered unaccounted receipt by the AO based on seized documents and statements made by Shri Vikas A. Shah. The CIT(A) concluded that the amount was a refund for a cancelled deal and not income chargeable to tax. The Tribunal upheld this decision, noting that the AO's assumption of the amount being dalali/brokerage was baseless and unsupported by any corroborative evidence.Assessment Year 2004-05:Similar to the previous year, the revenue's appeal against the deletion of Rs. 42.40 lakhs was based on the same grounds. The CIT(A) found no evidence supporting the AO's claim that the amount was unaccounted receipt. The Tribunal agreed with CIT(A), emphasizing that the findings were consistent with the previous year's decision and lacked corroborative evidence.Assessment Year 2005-06:For this year, the revenue contested the deletion of Rs. 91.50 lakhs, alleged as on-money payment. The AO also considered an addition of Rs. 44.80 lakhs as dalali/brokerage but did not make a separate addition. The CIT(A) deleted the Rs. 91.50 lakhs addition, citing lack of corroborative evidence and improbability of the transaction. The Tribunal upheld CIT(A)'s decision, noting that the valuation of the property was not challenged by the Stamp Duty Authority and that the AO failed to gather further evidence during remand proceedings.Conclusion:The Tribunal dismissed the revenue's appeals for all three assessment years, affirming the CIT(A)'s deletions of the additions. The cross objections by the assessee regarding the invocation of section 153C were also dismissed. The Tribunal emphasized the lack of corroborative evidence and the improbability of the transactions as key reasons for upholding CIT(A)'s decisions.

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