On-Money Addition Deleted; Third-Party Pen Drive & Statements Insufficient; Sec 153C Quashed: ITAT Mumbai

Pinkydevi Mahendrakumar Jain Vs ACIT (ITAT Mumbai) On-Money Addition Deleted in Platinum Mall Cases – Third-Party Pen Drive & Statements Not Sufficient – Sec 153C Addition Quashed – ITAT Mumbai Based on a search in Rubberwala Group, AO invoked sec 153C and added ₹5 lakh alleging cash payment (“on-money”) for purchase of shop in Platinum Mall, relying mainly on a pen drive, excel sheets and statement of a third-party employee. CIT(A) confirmed the addition. ITAT held that no incriminating material directly linked to the assessee—such as cash receipts, signed documents or corr...