Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Political contribution deductions under section 80GGC require proof of genuine payment, not merely banking-channel evidence and a receipt. The article explains that tax authorities may assess transactions through surrounding circumstances, human probabilities and the preponderance of probabilities where investigation material casts doubt on the recipient political party or contribution. Once the Revenue produces cogent circumstances suggesting accommodation entries, the taxpayer must substantiate the contribution, nexus with the party and reason for the payment. It further notes that denial of cross-examination does not necessarily breach natural justice where the taxpayer knew the allegations, had an opportunity to respond, and the conclusion rests on cumulative evidence rather than a single statement.
Political contribution deductions under section 80GGC require proof of genuine payment, not merely banking-channel evidence and a receipt. The article explains that tax authorities may assess transactions through surrounding circumstances, human probabilities and the preponderance of probabilities where investigation material casts doubt on the recipient political party or contribution. Once the Revenue produces cogent circumstances suggesting accommodation entries, the taxpayer must substantiate the contribution, nexus with the party and reason for the payment. It further notes that denial of cross-examination does not necessarily breach natural justice where the taxpayer knew the allegations, had an opportunity to respond, and the conclusion rests on cumulative evidence rather than a single statement.
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