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2022 (11) TMI 1168 - AT - Income TaxUnexplained investment u/s 69 - Advance receipt against sale of land - Transfer yet to be registered - Addition made on the basis incriminating documents - Dumb Document - "Saudha Chithi" found and seized during the course of search and seizure action - unaccounted land transactions - CIT(A) deleted the additions - HELD THAT:- We see no reasons to take any other view of the matter than the view so taken by the Division Bench of this Tribunal in in the case of Shri Pravinchandra Dahyabhai Umriger [2022 (5) TMI 1479 - ITAT SURAT] as held ‘sauda chithi’ is a dumb document as far as the assessee is concerned. Hence, the additions cannot be made on the basis of such dumb documents. As the issue is squarely covered in favour of the assessee by the decision of the Coordinate Bench(supra) and there is no change in facts and law and the Revenue is unable to produce any material to controvert the aforesaid findings of the Coordinate Bench (supra). We find no reason to interfere in the said order of the Coordinate Bench, therefore, respectfully following the binding judgment of the Coordinate Bench, we dismiss the appeal of the Revenue.
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