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Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
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