Section 69 Addition Cannot Rest Solely on Uncorroborated Third-Party Excel Sheet: ITAT Agra

Ranjana Gupta Vs ACIT (ITAT Agra) The assessee filed an appeal against the order of the Commissioner of Income-tax (Appeals)/NFAC for AY 2021-22. The Tribunal first condoned a delay of 52 days in filing the appeal after accepting that the delay resulted from the assessee’s serious illness, advanced age, continuous medical treatment, and inability to attend legal and administrative matters. The assessment arose after a search under Section 132 in the case of the Omaxe Group, during which a hard disk containing “MAIN REPORT” Excel files allegedly recorded unaccounted transactions. Based on...