Tribunal held that during search proceedings, not a single question about receipt of on money was enquired of the principal partner during the search statement recorded under section 131 of the Act. Seized documents incapable of testifying to partner’s receipt of on money, and addition was made on mere suspicion. Tribunal also held that extrapolation of receipt of on money for other flat purchasers and years was without any evidence. Addition was deleted.(AY. 2017-18 to 2019-20)
Ganraj Homes LLP v. ACIT (2025) 123 ITR 630 (Pune)(Trib)
S. 153A : Assessment-Search-Undisclosed income-Construction and property development-On money-Seized diaries-Statement of senior sales manager-Extrapolation of receipt of on money-Addition was made on guesswork and surmises-Addition was deleted. [S. 131, 132, 133A]
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