Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Section 69 applies only to investments not recorded in the assessee's books of account. Immovable properties recorded in the firm's regular books, together with corresponding identifiable partners' capital contributions, cannot be treated as unexplained investments where the books have not been found defective or rejected. Concerns about an individual partner's financial capacity must be examined in that partner's assessment and do not, by themselves, make the firm's recorded investment unexplained. Principles applicable to unexplained cash credits do not govern recorded investments under section 69. The addition for unexplained investment was therefore deleted, while the reassessment challenge was left academic.
Section 69 applies only to investments not recorded in the assessee's books of account. Immovable properties recorded in the firm's regular books, together with corresponding identifiable partners' capital contributions, cannot be treated as unexplained investments where the books have not been found defective or rejected. Concerns about an individual partner's financial capacity must be examined in that partner's assessment and do not, by themselves, make the firm's recorded investment unexplained. Principles applicable to unexplained cash credits do not govern recorded investments under section 69. The addition for unexplained investment was therefore deleted, while the reassessment challenge was left academic.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
