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...
Loose papers that are undated, unsigned and unlinked to the assessee cannot, by themselves, support additions for unexplained investment under section 69; the Tribunal treated the paper as a dumb document and deleted the addition. A figure on the same paper also could not be taxed as unexplained money under section 69A because no money or other valuable asset was found in the assessee's ownership, and the nature of the entry was not established; that addition was deleted. A gross profit addition based only on alleged stock shortage was rejected because the assessee gave a plausible job-work explanation that was not disproved. Third-party WhatsApp and police material could not be used without full disclosure or cross-examination, so the betting-related section 69A addition also failed.
Loose papers that are undated, unsigned and unlinked to the assessee cannot, by themselves, support additions for unexplained investment under section 69; the Tribunal treated the paper as a dumb document and deleted the addition. A figure on the same paper also could not be taxed as unexplained money under section 69A because no money or other valuable asset was found in the assessee's ownership, and the nature of the entry was not established; that addition was deleted. A gross profit addition based only on alleged stock shortage was rejected because the assessee gave a plausible job-work explanation that was not disproved. Third-party WhatsApp and police material could not be used without full disclosure or cross-examination, so the betting-related section 69A addition also failed.
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