Section 153C Additions Deleted – Hazir Johri Software Entries Held Unreliable Without Corroboration

Brijesh Kumar Verma Vs DCIT (ITAT Delhi)

The ITAT Delhi allowed the assessee’s appeals for AY 2016-17 & 2017-18 and deleted additions made u/s 69A based on entries found in the “Hazir Johri” software seized during search on Jindal Bullion Ltd (JBL) Group. The AO had treated peak credit of ₹70.27 lakh and estimated profit @2% as undisclosed transactions solely relying on digital ledger entries and statements of third-party employees. The Tribunal observed that the seized data belonged to JBL and not to the assessee; therefore presumption u/s 292C could n

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