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2021 (11) TMI 80 - AT - Income TaxReopening of assessment u/s 147 - Addition of payment made from an unaccounted sources - Addition based on soft copy of a deed found from the computer of deed writer - HELD THAT:- No copy signed by the assessee and seller parties with a transaction has been found during the course of the search of Sh Naresh Gupta. The deed writer, himself has denied of having aware of any money transaction between the parties, which was recorded in the computer. He stated during the course of search that amount mentioned may be as a result of cut/paste of various documents in the computer. We find that the Assessing Officer has made addition only on the basis of said unsigned deed and no corroborative evidences have been brought on record to show that purchase transaction was executed by the assessee at the rate mentioned in the computer of Sh. Naresh Sharma. Assessing Officer has not carried out any inquiries from the seller of the land also. The assessee cannot be penalised merely on the basis of an unsigned deed found from the premises of a third-party. In our opinion, the finding of the Ld. CIT(A) on the issue in dispute is well reasoned and we do not find any error in the same. - Decided in favour of assessee.
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