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Invalid 153C Satisfaction Note – No Nexus Between Seized Diary & Assessee; Addition Deleted
Case Law Details
- Case Name
- DCIT Vs Planet Infra Promoters P. Ltd. (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2013-14
- Courts
- All ITAT, ITAT Delhi
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DCIT Vs Planet Infra Promoters P. Ltd. (ITAT Delhi)
In this appeal the Revenue challenged the deletion of addition made by AO u/s 153A r.w.s. 153C, based on a seized loose sheet found in the search on Antriksh Group (05.02.2014). The AO recorded satisfaction on 02.03.2016 alleging that the seized page showing “Received from Ajit – 75 lakh” belonged to / pertained to Planet Infra Promoters Pvt. Ltd. & therefore issued notice u/s 153C. Assessment was completed treating the amount as unexplained income for AY 2013-14.
CIT(A) deleted the addition holding that the seized material did not ...
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