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The ITAT allowed the assessee trust's appeal, holding that additions under s.69A and s.69C based on documents seized from a third party cannot be imputed to the trust. Documents in the handwriting of the third party give rise to the statutory presumption under s.292C (read with s.132 and s.132(4A)) only as against that person, and the AO could not lawfully attribute those records to the assessee absent independent corroborative material seized from the trust or admissions. Consequently, the capitation-fee additions were unwarranted. Separately, interest and unsecured-loan additions were reversed as the loans and interest were reflected in audited books and AO's extrapolated adjustments were erroneous.
The ITAT allowed the assessee trust's appeal, holding that additions under s.69A and s.69C based on documents seized from a third party cannot be imputed to the trust. Documents in the handwriting of the third party give rise to the statutory presumption under s.292C (read with s.132 and s.132(4A)) only as against that person, and the AO could not lawfully attribute those records to the assessee absent independent corroborative material seized from the trust or admissions. Consequently, the capitation-fee additions were unwarranted. Separately, interest and unsecured-loan additions were reversed as the loans and interest were reflected in audited books and AO's extrapolated adjustments were erroneous.
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