Excel Sheet Not Sufficient Proof of Transaction with Developer: ITAT Allows Appeal [Read Order]
ITAT relied on precedent to hold that excel sheet is not sufficient proof.
![Excel Sheet Not Sufficient Proof of Transaction with Developer: ITAT Allows Appeal [Read Order]](https://images.taxscan.in/h-upload/2026/02/27/2127324-excel-sheet-not-sufficient-proofjpg.webp "Excel Sheet Not Sufficient Proof of Transaction with Developer: ITAT Allows Appeal [Read Order]")
The Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, held that an excel sheet is not sufficient proof of transaction with a third-party, in this case, developer. ITAT allowed the appeal ultimately. The assessee is a retired school teacher who has not filed return of income due to her income being below taxable income for Assessment Year (AY) 2019-20. On 30.05.2019,...
The Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, held that an excel sheet is not sufficient proof of transaction with a third-party, in this case, developer. ITAT allowed the appeal ultimately.
The assessee is a retired school teacher who has not filed return of income due to her income being below taxable income for Assessment Year (AY) 2019-20. On 30.05.2019, the Assessing Officer found one excel sheet wherein cash payment details were found.
The assessee’s name and PAN Number is reflected in the sheet and so a notice under Section 148A(b) dated 14.03.2023 was issued. An explanation was required as to why the income chargeable to tax amounting to INR 51,81,008/- has escaped assessment for AY 2019-20.
Assessee filed a reply on 22.03.2023 and explained that her income was INR 2,81,010/- which is below taxable income. With respect to the property purchase made, she said that the entire payment was made through cheques from SBI Bank Account and Post Office savings account and no cash payment was made. The AO was unsatisfied and passed an order under Section 148A(d) dated 20.03.2023.
The AO completed reassessment and made assessed income at INR 17,81,650/-. The Commissioner of Income Tax (Appeals) [CIT(A)] confirmed the addition made by AO.
When the matter came up before the tribunal bench comprising Narendra Prasad Sinha (Accountant Member) and T. R. Senthil Kumar (Judicial Member), it was observed that the assessee had not made any cash payment to the developer which was confirmed by the developer through a Notarized Affidavit dated 07.09.2023.
The ITAT made a reference to the case of PCIT, Central v. Kaushik Nanubhai Majithia (2024) wherein it was held that excel sheet found and seized during course of survey is not sufficient proof of transaction between the assessee and the developer.
Accordingly, the appeal was allowed and the additions were deleted.
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