Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT upheld the CIT(A)'s deletion of additions, holding that the satisfaction note did not identify any incriminating material seized that disclosed undisclosed income under s.153C; the transaction (sale consideration of Rs.10.43 crore) was already declared in the assesee's returns for AY 2012-13 and AY 2014-15 and assessed. The Tribunal found seized documents (including ikrarnamas and registered deed) related to the same disclosed transaction and were not shown to generate new incriminating information; revenue failed to demonstrate that seized material disclosed undisclosed income. Consequently, jurisdictional prerequisites for invoking s.153A read with s.153C were not satisfied, and the CIT(A) order deleting the addition was affirmed.
ITAT upheld the CIT(A)'s deletion of additions, holding that the satisfaction note did not identify any incriminating material seized that disclosed undisclosed income under s.153C; the transaction (sale consideration of Rs.10.43 crore) was already declared in the assesee's returns for AY 2012-13 and AY 2014-15 and assessed. The Tribunal found seized documents (including ikrarnamas and registered deed) related to the same disclosed transaction and were not shown to generate new incriminating information; revenue failed to demonstrate that seized material disclosed undisclosed income. Consequently, jurisdictional prerequisites for invoking s.153A read with s.153C were not satisfied, and the CIT(A) order deleting the addition was affirmed.
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