Shrigopal Rameshkumar Sales (P) Ltd. v. Dy.CIT (2025) 233 TTJ 747 / 246 DTR 51 (Nag)(Trib)

S. 153A: Assessment-Search-Undisclosed income-Document referred to and relied upon by the AO does not bear any signature of the assessee-Addition is deleted-Appellate Tribunal-Delay of 702 days in filing the appeal is condoned. [S. 254(1)]

The Tribunal condoned the delay of 702 days in filing of an appeal. On merit the Tribunal held that in the absence of any corroborative evidence to suggest that assessee has actually received unaccounted cash impugned addition made by the AO solely on the basis of an unsigned document seized during the course of search is not sustainable, particularly when no enquiry of whatsoever nature was made by the AO from the broker who allegedly prepared the impugned document or from GM Group which allegedly made the payment of the said sum and the assessee has explained that the same represents letters of credit received by it from the GM group against the sales made to the said group.  Addition is deleted. (AY. 2015-16)

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