https://www.taxtmi.com/caselaws?id=765217 ITAT Delhi ruled in favor of the assessee company in an assessment under section 153A. The tribunal held that diary entries seized from a third party's residential premises could not incriminate the assessee company without irrefutable evidence establishing culpability. The Revenue failed to connect the seized entries to the assessee company and discharge the burden of proof. The tribunal found no jurisdiction under section 153A for making additions without incriminating material, and noted that simultaneous additions in other entities' hands undermined the Revenue's case. The additions were deleted as unjustified. en-us Wed, 15 Jan 2025 00:00:00 +0530 Tue, 28 Jan 2025 08:24:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765217 ITAT Delhi ruled in favor of the assessee company in an assessment under section 153A. The tribunal held that diary entries seized from a third party's residential premises could not incriminate the assessee company without irrefutable evidence establishing culpability. The Revenue failed to connect the seized entries to the assessee company and discharge the burden of proof. The tribunal found no jurisdiction under section 153A for making additions without incriminating material, and noted that simultaneous additions in other entities' hands undermined the Revenue's case. The additions were deleted as unjustified. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765217