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ITAT allowed the assessee-trust's appeal and deleted the addition made u/s 69C. The Tribunal held that the addition was based solely on third-party statements recorded during search, without any seized material, bank trail, or corroborative evidence establishing that the donation was returned in cash after commission. The assessee was not confronted with such statements despite specific request, vitiating reliance on them. ITAT reiterated that uncorroborated search statements and mere suspicion cannot substitute legal proof. As the donation was made through banking channels to a registered charitable trust holding valid s.12A and s.80G registrations, and duly recorded in books, the assessee had discharged its onus. Section 69C was held inapplicable and the inter-trust donation treated as valid application of income u/s 11.
ITAT allowed the assessee-trust's appeal and deleted the addition made u/s 69C. The Tribunal held that the addition was based solely on third-party statements recorded during search, without any seized material, bank trail, or corroborative evidence establishing that the donation was returned in cash after commission. The assessee was not confronted with such statements despite specific request, vitiating reliance on them. ITAT reiterated that uncorroborated search statements and mere suspicion cannot substitute legal proof. As the donation was made through banking channels to a registered charitable trust holding valid s.12A and s.80G registrations, and duly recorded in books, the assessee had discharged its onus. Section 69C was held inapplicable and the inter-trust donation treated as valid application of income u/s 11.
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