Indian Tax Update - ITAT restricts section 153C additions, requires year-specific evidence, prevents double taxation on land investments

[Admin(Portal)]

ITAT restricts section 153C additions, requires year-specific evidence, prevents double taxation on land investments

ITAT upheld CIT(A)'s decision restricting additions under section 153C search assessments. For unaccounted receipts, ITAT confirmed 20% profit margin on verifiable on-money receipts for AY 2015-16 only, deleting extrapolated additions for subsequent years lacking year-specific incriminating material. The tribunal emphasized that additions in non-abated assessments require incriminating documents relatable to specific assessment years. Regarding unaccounted land investment under section 69, ITAT deleted additions finding payments sourced from already-taxed unaccounted receipts, preventing double taxation. For alleged unaccounted cash expenditure under section 69C, ITAT upheld deletion as seized documents from third-party premises lacked nexus to assessee's business, with AO failing to establish connection through proper enquiry or corroboration.


Categories: Income Tax, Highlights, TaxLaws, TaxTMI
Source: https://www.taxtmi.com/highlights?id=89989 Jul 01, 2025, 10:00 AM