PCIT Vs Global Tech Park Pvt. Ltd. (Karnataka High Court)
Scribbled Figures Are Not ₹10 Crore Income: Karnataka HC Rejects Addition Based on Loose Sheet
Loose Sheet Without Corroborative Evidence Cannot Establish Undisclosed Cash Payment
The Karnataka High Court has upheld the deletion of an addition of ₹10 crore made solely on the basis of figures scribbled on loose sheets found during a search.
The Court found that the figures appearing on the loose sheets were not supported by any material showing that the assessee had actually paid cash over and above the consideration disclosed in the registered sale deed. No evidence of withdrawal, movement or receipt of unaccounted money was discovered during the search.
The Court held that the legal position concerning uncorroborated loose sheets was already settled by the Supreme Court in Central Bureau of Investigation v. V.C. Shukla and by the Karnataka High Court in Deputy Commissioner of Income Tax v. Sunil Kumar Sharma.
Consequently, no substantial question of law arose under Section 260A, and the Revenue’s appeal was dismissed.
Search Conducted at Assessee’s Premises
Global Tech Park Pvt. Ltd. filed its original return of income for Assessment Year 2016-17 on October 17, 2016, declaring nil income.
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