Addition Partly Deleted as Section 69A Cannot Apply to Mere Documents Found in Search

Sanjay Wahi Vs ACIT (ITAT Delhi)

Section 69A Cannot Apply to Mere Seized Documents – Delhi ITAT Recasts Undisclosed Commission, Restricts Addition to 20% of Gross Commission

Delhi ITAT examined an addition made during search proceedings where a seized document reflected gross commission receipts of Rs.11,63,955/-.

AO treated the entire gross commission as unexplained money u/s 69A, & CIT(A) confirmed the view holding that the document was not a dumb paper & that no evidence of expense allocation or sharing arrangement with franchises/investo

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