Tribunal allows appeal, deletes Rs. 13L, Rs. 11L, and Rs. 10L additions. Assessee's evidence deemed sufficient.

The Tribunal allowed the appeal, directing the deletion of additions of Rs. 13 lakhs, Rs. 11 lakhs, and Rs. 10 lakhs. It concluded that the assessee's explanations and documentary evidence sufficiently substantiated the sources of the amounts. The order was pronounced on 28.10.2022.

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Issues Involved:
1. Violation of principles of natural justice.
2. Addition of Rs. 13 lakhs as undisclosed income.
3. Addition of Rs. 11 lakhs despite substantiated transactions.
4. Addition of Rs. 10 lakhs despite explanations and supporting documents.
5. Request for consequential relief and legal claims.

Detailed Analysis:

Violation of Principles of Natural Justice:
The assessee did not press this ground; hence, it was dismissed as 'not pressed.'

Addition of Rs. 13 Lakhs as Undisclosed Income:
The assessee challenged the addition of Rs. 13 lakhs, arguing that the amount was seized by the CBI and was part of a property transaction. The assessee provided documentary evidence, including a purchase deed, sale deed, bank statements, and a seizure memo, to substantiate the source of the amount. The Tribunal noted that there was no case registered against the assessee by the CBI, and the amount seized was part of a property transaction with Shri Ashwani Kumar Sharma. The Tribunal concluded that the source of Rs. 13 lakhs was discernible from the documentary evidence and directed the AO to delete the addition.

Addition of Rs. 11 Lakhs Despite Substantiated Transactions:
The assessee argued that the remaining amount of Rs. 17 lakhs was handed over to the CBI under duress and was obtained through unsecured loans from known individuals. The AO accepted loans from two individuals but disputed the creditworthiness of three others. The Tribunal examined the evidence, including affidavits, Aadhar cards, bank statements, and J-Forms, and concluded that the identity, creditworthiness, and genuineness of the transactions were established. The Tribunal directed the deletion of the addition of Rs. 11 lakhs.

Addition of Rs. 10 Lakhs Despite Explanations and Supporting Documents:
The assessee contended that the amount of Rs. 10 lakhs credited to her bank account was part of an advance received under an agreement to sell her property. The Tribunal reviewed the evidence, including the purchase deed, bank passbook, and agreement details, and found that the amount was indeed an advance against the sale of the property. The Tribunal directed the AO to delete the addition of Rs. 10 lakhs.

Request for Consequential Relief and Legal Claims:
This ground was general and required no adjudication.

Conclusion:
The Tribunal allowed the appeal filed by the assessee, directing the deletion of the additions of Rs. 13 lakhs, Rs. 11 lakhs, and Rs. 10 lakhs, and concluded that the assessee's explanations and documentary evidence were sufficient to substantiate the sources of the amounts in question. The order was pronounced in the open court on 28.10.2022.

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