Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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