Commission Allegation Based on Dumb Excel Sheet Rejected by ITAT Delhi

DCIT Vs Udai Shanker Awasthi (ITAT Delhi) Section 153C Jurisdiction Invalid in Absence of Incriminating Material — Commission Allegation Based on Dumb Excel Sheet Rejected: Revenue filed appeals against deletion of additions made u/s 153C r.w.s.143(3) alleging undisclosed commission income routed through overseas entities. The Tribunal dismissed Revenue’s appeals holding that assumption of jurisdiction itself was invalid due to absence of incriminating material belonging or relating to the assessee. The alleged case was built mainly on statements of third parties and an excel sheet created...