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ITAT ruled that entries discovered in a seized diary from RKY's premises were insufficient to establish liability against the assessee company u/s 153A. The Revenue failed to demonstrate a conclusive link between the diary entries and the assessee company's transactions. The tribunal emphasized that statutory presumption was inapplicable, and the burden of proof remained with Revenue to establish transaction authenticity. The simultaneous addition of these entries to another entity's assessment further undermined Revenue's position. ITAT held in favor of the assessee on dual grounds: lack of jurisdiction u/s 153A absent incriminating evidence, and failure to substantiate that entries exclusively pertained to the assessee company.
ITAT ruled that entries discovered in a seized diary from RKY's premises were insufficient to establish liability against the assessee company u/s 153A. The Revenue failed to demonstrate a conclusive link between the diary entries and the assessee company's transactions. The tribunal emphasized that statutory presumption was inapplicable, and the burden of proof remained with Revenue to establish transaction authenticity. The simultaneous addition of these entries to another entity's assessment further undermined Revenue's position. ITAT held in favor of the assessee on dual grounds: lack of jurisdiction u/s 153A absent incriminating evidence, and failure to substantiate that entries exclusively pertained to the assessee company.
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