Held that merely on the basis of contents of the WhatsApp amongst partners and statement of partner addition is not justified when there is huge gap between date of communication and sale of flats. Order of CIT(A) deletion of addition is affirmed. As regards addition as undisclosed income in respect of on money, addition is sustained to the extent of 10 percent of on-money. (AY. 2014-15 to 2016-17)
ACIT v. Kush Corporation (2023) 226 TTJ 55 (UO) (Surat)(Trib)
S. 153A : Assessment-Search-On money-Contents of the WhatsApp amongst partners-Statement of partner-Huge gap between date of communication and sale of flats-Deletion of addition is affirmed-Undisclosed income-On money-addition is sustained to the extent of 10 percent of on-money.[ S. 132]