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ITAT upheld the AO's invocation of section 153C against the assessee, finding the seized gift deed to be an incriminating document belonging to the assessee and rejecting the contention that no incriminating material was found. However, ITAT deleted additions under section 69 read with section 115BBE insofar as the AO and CIT(A) taxed the entire alleged gift of Rs. 22,40,000 and treated specified bank transfers as routed cash without any inquiry or cogent evidence. ITAT accepted the assessee's contention as to a draft deed and disallowed those additions, but identified an unexplained residual sum of Rs. 1,45,430 requiring factual verification. The matter is remitted to the AO for fresh inquiry and determination.
ITAT upheld the AO's invocation of section 153C against the assessee, finding the seized gift deed to be an incriminating document belonging to the assessee and rejecting the contention that no incriminating material was found. However, ITAT deleted additions under section 69 read with section 115BBE insofar as the AO and CIT(A) taxed the entire alleged gift of Rs. 22,40,000 and treated specified bank transfers as routed cash without any inquiry or cogent evidence. ITAT accepted the assessee's contention as to a draft deed and disallowed those additions, but identified an unexplained residual sum of Rs. 1,45,430 requiring factual verification. The matter is remitted to the AO for fresh inquiry and determination.
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