ITAT Delhi Quashes Addition Based on ‘Dumb Documents’ in Section 153C Proceedings
In a significant ruling, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has quashed an income tax addition based on ‘dumb documents’ in the case of ACIT vs. New World Buildcon (ITA No. 5051/Del/2012).
The bench, comprising Satbeer Singh Godara (Judicial Member) and S. Rifaur Rahman (Accountant Member), observed that rough jottings and an alleged map seized during the search on M/s. Kohinoor Foods Ltd. did not conclusively establish any on-money payment or receipt involving the assessee. Since the documents neither mentioned the assessee’s name nor satisfied the criteria of “belonging” to the taxpayer, the ITAT ruled that Section 153C proceedings could not be justified.
This decision reinforces the principle that additions cannot be made merely on the basis of unsubstantiated documents without clear evidentiary value.
The Copy Of the order is as under:
