ITAT allowed the individual assessee's appeal and dismissed the Revenue's appeal. It held the approval u/s 153D invalid as the JCIT granted omnibus approval for 98 cases on the same day and from a distant station, rendering the assessment order void ab initio. On merits, ITAT accepted that unexplained cash found during search belonged to group companies, as it matched their cash books, and treated the assessee's prior surrender as made under pressure without corroborative evidence. It upheld CIT(A)'s view that assessment should have been initiated u/s 153C, not u/s 143(3). Additions towards jewellery were deleted considering CBDT circular, assessee's high net worth and disclosed income. ITAT also rejected additions based on uncertified electronic data lacking s.65B compliance.
ITAT allowed the individual assessee's appeal and dismissed the Revenue's appeal. It held the approval u/s 153D invalid as the JCIT granted omnibus approval for 98 cases on the same day and from a distant station, rendering the assessment order void ab initio. On merits, ITAT accepted that unexplained cash found during search belonged to group companies, as it matched their cash books, and treated the assessee's prior surrender as made under pressure without corroborative evidence. It upheld CIT(A)'s view that assessment should have been initiated u/s 153C, not u/s 143(3). Additions towards jewellery were deleted considering CBDT circular, assessee's high net worth and disclosed income. ITAT also rejected additions based on uncertified electronic data lacking s.65B compliance.
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