Case Law Details
Amit Katyal Vs DCIT (ITAT Delhi)
The case of Amit Katyal vs. DCIT (ITAT Delhi) revolves around the addition of Rs. 5 crores to the declared income of the assessee based on an email, which was found during a search operation. The main legal issue was whether this addition could be justified without any corroborative evidence supporting the email’s contents. The Income Tax Appellate Tribunal (ITAT) Delhi ruled in favor of the assessee, highlighting several critical points.
Background and Grounds of Appeal
The appeal in question pertains to the Assessment Year (AY) 2012-13 and arises from the order passed by the Commissioner of Income Tax (Appeals) [CIT(A)], which confirmed the addition of Rs. 5 crores to the income of Amit Katyal. The addition was based solely on an email exchanged between the assessee and Mr. Gulbir (Juno) Madan, which was found during a search operation at the premises of M/s. Frost Falcon Distilleries Pvt. Ltd, a company associated with the Krrish Group of companies.
The assessee argued that:
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