Ekta Housing Pvt. Ltd. v. Dy. CIT (2021) 89 ITR 56 (Mum.)(Trib.)

S. 153A : Assessment-Search or requisition-Income from undisclosed sources-On money-Only estimated income element embedded in such receipt can be taxed-15 % of receipts was accepted by group concerns by Settlement Commission-15% was accepted as reasonable-Merely on the basis of statement of employee u/s. 131 without any incriminating material-Addition cannot be made. [S. 131]

Held that merely on the basis of statement of employee u/s 131 without any incriminating material, addition cannot  be made. Tribunal also held that  only estimated income element embedded in such receipt can be taxed.  Settlement Commission has accepted 15 % of receipts was accepted by group concerns, accordingly 15% was accepted as reasonable. (AY. 2013-14, 2014-15, 2015-16, 2016-17)