Section 153C Addition U/s 69 Deleted – Third Party Statement Loose Paper Held Insufficient

Kavita Gupta Vs DCIT (ITAT Delhi) The ITAT Delhi allowed the assessee’s appeal and quashed assessment framed u/s 153C along with addition of ₹50 lakh made u/s 69 for alleged cash investment in a Noida flat. The Tribunal observed that proceedings were initiated merely on the basis of a loose paper containing the assessee’s name found during search in Hans Group and statements of third parties, without any seized material belonging to the assessee or corroborative evidence. It held that denial of cross-examination of the persons whose statements were relied upon violated principles of natu...