Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
For unexplained investment in property purchases, an addition under section 69 cannot rest solely on an unauthenticated loose sheet seized from a third party. The notes state that the sheet was unsigned, not part of regular accounts, inconsistent with registered conveyance and banking records, and unconnected to the assessee or sellers. Without proof of the document's author, independent seller enquiries, evidence of on-money receipt, a cash trail, or other corroboration, the Revenue does not discharge its burden to prove understated consideration. Loose sheets or dumb documents are not substantive evidence by themselves, and suspicion cannot replace proof. The addition was deleted; issues concerning section 153C validity, the satisfaction note, and cross-examination remained open.
For unexplained investment in property purchases, an addition under section 69 cannot rest solely on an unauthenticated loose sheet seized from a third party. The notes state that the sheet was unsigned, not part of regular accounts, inconsistent with registered conveyance and banking records, and unconnected to the assessee or sellers. Without proof of the document's author, independent seller enquiries, evidence of on-money receipt, a cash trail, or other corroboration, the Revenue does not discharge its burden to prove understated consideration. Loose sheets or dumb documents are not substantive evidence by themselves, and suspicion cannot replace proof. The addition was deleted; issues concerning section 153C validity, the satisfaction note, and cross-examination remained open.
Note: It is a system-generated summary and is for quick reference only.
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