ITAT Dismisses Rs. 24 Crore Additions Over Third-Party Documents

DCIT Vs Shree Siddhi Infrabuild Pvt. Ltd. (ITAT Ahmedabad)

Sahara Diaries Logic Applies—Third-Party Diary Cannot Tax Assessee -No Name, No Nexus, No Cash Trail- Rs.24+ Crore Additions Collapse

AO made huge additions u/s 68 & 69A across three years based solely on a seized coded diary/cash-book of Venus Group, decoded by AO to allege unaccounted cash dealings with Assessee. AO assumed that the name “Kalpesh” in seized diary referred to Assessee’s director & treated decoded entries as evidence of cash exchanges of Rs.4 crore, Rs.7.5 crore, Rs.1

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