Invalid 153C Satisfaction Note – No Nexus Between Seized Diary & Assessee; Addition Deleted

DCIT Vs Planet Infra Promoters P. Ltd. (ITAT Delhi) In this appeal the Revenue challenged the deletion of addition made by AO u/s 153A r.w.s. 153C, based on a seized loose sheet found in the search on Antriksh Group (05.02.2014). The AO recorded satisfaction on 02.03.2016 alleging that the seized page showing “Received from Ajit – 75 lakh” belonged to / pertained to Planet Infra Promoters Pvt. Ltd. & therefore issued notice u/s 153C. Assessment was completed treating the amount as unexplained income for AY 2013-14. CIT(A) deleted the addition holding that the seized material did not ...