Held that the seized document based on which the addition was made, could not be considered as relating to this AY. The assessee claimed that he has sufficient sources for making payment of the balance amount in the the seized documents. The documents mentioned the assessee’s share at 30 per cent. Therefore, out of the remaining amount, only 30 per cent. being the assessee’s share as mentioned could be added. (AY. 2012-13 to 2015-16).
Pujala Mahesh Babu v.Asst. CIT (2023)101 ITR 458 (Hyd) (Trib)
S. 69 : Unexplained investments-Unexplained expenditure-Additions on the basis of seized documents-Cannot explain source-Amount not pertaining to assessment year-Addition not sustainable-Share of assessee at 30% as per seized documents-Addition to that extent only.