Addition Under 115BBE Struck Down for Procedural Lapses

Amarjot Singh Sohi Vs ITO (ITAT Chandigarh) On-Money Addition Fails Without Proof: Third-Party Excel Sheet Not Enough The Chandigarh Bench of the Income Tax Appellate Tribunal (ITAT) deleted the addition of ₹8 lakh made under section 69 read with section 115BBE, holding that the Revenue failed to prove any actual cash payment (“on-money”) by the assessee for purchase of a shop. The reassessment was initiated solely on the basis of information arising from a search on the seller group (Omaxe Ltd.), wherein an Excel sheet recovered from a third party allegedly reflected cash payments. The ...