Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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Bogus political donation claims under section 80GGC require the assessee to prove that the donation satisfies the statutory conditions for deduction; mere bank transfer, donation receipt, or the political party's registration is not enough. Where search material, statements, bank trail analysis and surrounding circumstances show the party acted as a conduit in an accommodation entry arrangement, authorities may apply human probabilities and the preponderance of probabilities to find the transaction -genuine, without direct proof of cash return being indispensable. Once such a cogent chain is established, the burden shifts to the assessee to rebut it with credible material. The deduction was disallowed and the appeal was dismissed.
Bogus political donation claims under section 80GGC require the assessee to prove that the donation satisfies the statutory conditions for deduction; mere bank transfer, donation receipt, or the political party's registration is not enough. Where search material, statements, bank trail analysis and surrounding circumstances show the party acted as a conduit in an accommodation entry arrangement, authorities may apply human probabilities and the preponderance of probabilities to find the transaction -genuine, without direct proof of cash return being indispensable. Once such a cogent chain is established, the burden shifts to the assessee to rebut it with credible material. The deduction was disallowed and the appeal was dismissed.
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