Rebuttable Presumption under Section 292C Cannot Be Applied Mechanically: ITAT Delhi

Krishna Gopal Saraf Vs ACIT (ITAT Delhi) These two appeals were filed by Krishna Gopal Saraf before the Income Tax Appellate Tribunal (ITAT), Delhi, against the orders of the Commissioner of Income Tax (Appeals)-29, New Delhi, dated 22 April 2017, relating to Assessment Years (AYs) 2013–14 and 2014–15. Since the issues involved were common, both appeals were heard together and decided by a single order. Appeal for AY 2013–14 (ITA No. 4564/Del/2017) The assessee raised several grounds, mainly contesting the legality of the search conducted under section 132, the validity of the assessmen...