ITAT Deletes Additions Due to Unreliable Third-Party Evidence in 153C Proceedings

DCIT Vs Sanjay Jain (ITAT Delhi) Summary: The ITAT Delhi upheld the order of the CIT(A) deleting additions made under Section 153C, holding that the evidence relied upon by the Assessing Officer lacked credibility and evidentiary value. The case arose from search proceedings alleging receipt of kickbacks and accommodation entries based on electronic chats, third-party statements, and documents obtained from other investigations. The Tribunal noted that key evidence, including statements of a third party and summary sheets, was unreliable, non-contemporaneous, and in some instances created lat...