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Section 263 Set Aside for Relying on Uncorroborated Dumb Documents From Third-Party Search
Case Law Details
- Case Name
- Malay Multani Vs PCIT (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Ahmedabad
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Malay Multani Vs PCIT (ITAT Ahmedabad)
Dumb Document Can’t Trigger 263: ITAT Ahmedabad Quashes Revision on Unproved TDR Cash Payment
The ITAT quashed the Section 263 revision after holding that the Assessing Officer had already conducted proper enquiries into seized material, statements, bank records, and the TDR transaction. The Tribunal found that the PCIT relied on uncorroborated “dumb documents” from a third-party search, misread loose notings that lacked any nexus to the assessee, and even shifted allegations inconsistently between an individual and a firm. Since th...
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