No Incriminating Material, No 153C – ITAT Bangalore Deletes ₹150+ Cr Additions in JDA Case

Shantha Alias Shanthamma Vs DCIT (ITAT Bangalore)

Bangalore Tribunal has quashed the assessment framed u/s 153C & deleted additions exceeding ₹150 crores made on account of capital gains, business income, & deposits. Tribunal held that in the absence of incriminating material, proceedings u/s 153C were invalid & further found multiple jurisdictional defects in the assessment order.

Assessee & her husband had entered into Joint Development Agreements with M/s SJR Prime Corporation Pvt Ltd (2012) & M/s Sunil Mantri Realty Ltd (2009). On the basis of these

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