Section 153A Additions Made Without Incriminating Material are Invalid: ITAT Delhi

Sunil Garg Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT) in Delhi has ruled in favor of Sunil Garg, an assessee, in six separate appeals covering assessment years 2009-10 to 2014-15. The Tribunal deleted additions of gross profit that the Assessing Officer (AO) had made to the assessee’s declared income. The AO’s additions were upheld by the Commissioner of Income Tax (Appeals), but the Tribunal found them to be unsustainable based on facts and judicial precedents. The Issue and Assessee’s Arguments The primary issue in all six appeals was the AO’s arbit...