Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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.
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