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Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuine contributions.
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The test of human probabilities permits tax authorities to look beyond documentary evidence and banking-channel payments when assessing the real nature of a political contribution. Donation receipts and bank payments did not prove genuineness where investigation material, statements, bank-trail analysis, and the recipient party's modus operandi showed systematic fund layering for accommodation entries. The apparent transaction was not a genuine political contribution; the claimed deduction was denied, the consequential addition sustained, and the assessee's appeal dismissed.
The test of human probabilities permits tax authorities to look beyond documentary evidence and banking-channel payments when assessing the real nature of a political contribution. Donation receipts and bank payments did not prove genuineness where investigation material, statements, bank-trail analysis, and the recipient party's modus operandi showed systematic fund layering for accommodation entries. The apparent transaction was not a genuine political contribution; the claimed deduction was denied, the consequential addition sustained, and the assessee's appeal dismissed.
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