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...
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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