Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Uncorroborated WhatsApp chats, incomplete promissory-note images and vague seized notings were treated as insufficient to sustain additions for undisclosed income where no cash trail, confirmations, statements or other primary evidence was produced. Proposed land and flat deals that never materialised could not support investment or on-money additions, and notional interest could not be taxed again where the same income had already been assessed elsewhere. Brokerage arising from intermediary real estate transactions was treated as business income and restricted to 2%, while telescoping of source and application was directed on verification. Jewellery found in a locker was also accepted within the prescribed household limits.
Uncorroborated WhatsApp chats, incomplete promissory-note images and vague seized notings were treated as insufficient to sustain additions for undisclosed income where no cash trail, confirmations, statements or other primary evidence was produced. Proposed land and flat deals that never materialised could not support investment or on-money additions, and notional interest could not be taxed again where the same income had already been assessed elsewhere. Brokerage arising from intermediary real estate transactions was treated as business income and restricted to 2%, while telescoping of source and application was directed on verification. Jewellery found in a locker was also accepted within the prescribed household limits.
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