Neelu Sanjay Gupta (Smt.) Legal Heir of Late Sanjay Gupta v. Dy.CIT (2025) 233 TTJ 29 (Ahd) (Trib)

S. 153A: Assessment-Search-Revenue followed detailed guidelines during the search-Approval under the section cannot be considered as granted mechanically-Matter is restored to CIT(A). [S. 153D]

The ITAT Ahmedabad upheld the Revenue’s stance, rejecting claims that approvals under Section 153D were granted mechanically and that additions were made without reference to incriminating material found during the search. The Tribunal noted that detailed guidelines for search assessments were followed, and incriminating material revealed discrepancies such as unexplained loans, cash deposits, and manipulated entries in the books of accounts. The matter was restored to CIT(A) for further probe. AY. 2005-06,  2006-07)

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