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]

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)