Lalit Premchandani v. ITO (IT& TP) (2023) 203 ITD 416 (Indore) (Trib.)

S. 147 : Reassessment-Unaccounted on-money in cash-Date of payment as 5-11-2013-No addition can be made for the relevant assessment year.[S.69 , 148]

assessee, an NRI. Assessing Officer on the basis of  information that assessee purchased a property for a higher price but declared less consideration in sale deed. AO  held that  the assessee had paid unaccounted on-money in cash from undisclosed sources which had escaped assessment and he made addition under section 69. On appeal the Tribunal held that   document on basis of which reassessment was initiated clearly showed date of payment as 5-11-2013 which fell within previous year 2013-14 relevant to assessment year 2014-15 and  there was no cash-payment during previous year 2012-13 relevant to concerned assessment year 2013-14. Addition is deleted. (AY. 2013-14)