Addition u/s 68 of the Income Tax Act based on generalized external information unsustainable

Nitan Chhatwal Krishani Vs DCIT (ITAT Mumbai) ITAT Mumbai held that addition of capital gain as unexplained cash credit u/s 68 of the Income Tax Act is unsustainable on the basis of generalized external information as it cannot be considered as incriminating material found during the course of search. Facts- The assessee had filed his return of income for this year u/s 139(1) of the Act on 29-09-2013 declaring total income of Rs.3,57,59,670/-. The AO completed the assessment u/s 143(3) of the Act on 31.3.2015 accepting the return of income filed by the assessee. The revenue carried out search ...