The Assessing Officer made addition based on the incriminating documents found in search of assessee’s premises in the form of written and signed “Sauda Chithhi” treating the unaccounted transactions of land. On appeal the CIT(A) held that land was not transferred. Tribunal treated the document as a dumb document and affirmed the order of CIT(A). On appeal by Revenue High Court affirmed the order of the Tribunal. (AY. 2017-18)
PCIT (C) v. Prabodhchandra Jayantilal Patel (2023) 294 Taxman 440 (Guj.)(HC)
S. 69B : Amounts of investments not fully disclosed in books of account-Sauda Chithhi-Dumb documents-Incriminating documents-Sale of land-Land was not transferred-Deletion of addition by the Tribunal is affirmed. [S. 45, 260A]