Held that the Developer MBDL Pvt Ltd having owned up all the ‘N Trading Co. cloud data found during the course of the search at their office premises as belonging to it and offered the on-money receipt from various real estate projects by way of additional income before the Settlement Commission which has been accepted by the latter in its order. Addition made on account of on-money receipts in the hands of the assessee (landowner) on the basis of same cloud data cannot be sustained in the absence of any evidence to indicate that the assessee has received any share in the on-money received by MBDL Pvt Ltd. Appeal of the Revenue was dismissed. (AY.2013-14, 2014-15, 2015-16)
Dy. CIT v. Late Smt. Puspa Goyal Through Legal Munna Lal Goyal (2022) 217 TTJ 65 (UO)(Jaipur) (Trib)
S. 143(3) : Assessment-Search-On money-Trading data found in the cloud-Settlement commission accepting the application in the assessment of declarant-No evidence of on money received by the assessee-Deletion of addition is held to be justified. [S. 68, 69, 115BBE, 132 (4A), 153C, 245D(4), 292C]