Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Unexplained investment in immovable property under section 69 was held explained where the assessee produced the sale deed, the father's bank statement, and proof of direct payment to the seller through banking channels. The Tribunal held that this discharged the primary onus; the burden then shifted to the Revenue to bring adverse material, which it did not. Mere suspicion about antecedent credits in the father's account was insufficient, and the absence of a formal gift deed did not by itself make the investment unexplained in a family transaction. The addition was deleted in full.
Unexplained investment in immovable property under section 69 was held explained where the assessee produced the sale deed, the father's bank statement, and proof of direct payment to the seller through banking channels. The Tribunal held that this discharged the primary onus; the burden then shifted to the Revenue to bring adverse material, which it did not. Mere suspicion about antecedent credits in the father's account was insufficient, and the absence of a formal gift deed did not by itself make the investment unexplained in a family transaction. The addition was deleted in full.
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