ITAT Mumbai – Additions U/s 68 & 69D in Search Case Deleted; No Incriminating Material for Unabated Years & Mere Statements Insufficient

Mansukhlal Meghji Dodhia Vs DCIT (ITAT Mumbai) In Mansukhlal Meghji Dodhia (AYs 2012-13 to 2016-17), additions were made u/s 69D for alleged hundi cash loans and u/s 68 for unsecured loan from M/s Vinam Finance Pvt. Ltd. based on seized papers, investigation reports and third-party statements. The ITAT held that for unabated assessment years, additions under s.153A cannot survive in absence of year-specific incriminating material, relying on the Supreme Court ruling in Abhisar Buildwell. The seized documents were treated as loose papers/promissory notes without corroboration of actual cash mov...