Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
In completed or unabated assessments under section 153A, additions are confined to incriminating material found during the search; material already available with the Revenue, such as the HSBC Geneva Base Note, cannot by itself support an addition. Applying that rule, the article notes that the additions for the relevant year were unsustainable because no incriminating search material linked to them was found. On section 69A, the threshold requirement is proof that the assessee owned the money or asset; where the foreign accounts stood in third-party names and the Revenue could not prove ownership, the additions were properly deleted.
In completed or unabated assessments under section 153A, additions are confined to incriminating material found during the search; material already available with the Revenue, such as the HSBC Geneva Base Note, cannot by itself support an addition. Applying that rule, the article notes that the additions for the relevant year were unsustainable because no incriminating search material linked to them was found. On section 69A, the threshold requirement is proof that the assessee owned the money or asset; where the foreign accounts stood in third-party names and the Revenue could not prove ownership, the additions were properly deleted.
Note: It is a system-generated summary and is for quick reference only.
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