ACIT Vs Indeed Fincap Pvt. Ltd. (ITAT Delhi)
The Income Tax Appellate Tribunal (ITAT), Delhi, dismissed the Revenue’s appeal and upheld the order of the Commissioner of Income Tax (Appeals), which had quashed the assessment made under Section 153C of the Income-tax Act for Assessment Year 2014-15. The Revenue had challenged the deletion of additions of ₹29 lakh under Section 68 and ₹4.40 crore under Section 69A, as well as the finding that the assumption of jurisdiction under Section 153C was invalid.
The Revenue contended that a search conducted on the SMC Global Securities group led to the seizure of digital evidence, including emails and Excel sheets, allegedly showing unaccounted cash transactions involving the assessee. It argued that the Assessing Officer had validly recorded a consolidated satisfaction note covering multiple assessment years because the seized material related to several years, and that the additions were supported by incriminating digital evidence corroborated by bank transactions.
The assessee challenged the validity of the proceedings, contending that the jurisdiction under Section 153C was assumed on the basis of a consolidated satisfaction note for seven assessment years without any year-wise analysis of the seized material or year-specific satisfaction demonstrating how the material affected the determination of income for the relevant assessment year. It also argued that the proceedings were barred by limitation.
