Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Additions u/s 68 - Any appellate authority cannot reject the evidences without any discussion or reason. The CIT (A) has not mentioned as to what more evidence were needed to be produced by the assessee to substantiate its contention or what are the material or information to rebut the assessee’s explanation and evidences as discussed above. AO as well as the CIT(A) failed to appreciate or consider the more than sufficient evidences placed on record by the assessee to discharge the onus u/s 68 - Addition made u/s 68 of the Act is hereby deleted. - AT
Additions u/s 68 - Any appellate authority cannot reject the evidences without any discussion or reason. The CIT (A) has not mentioned as to what more evidence were needed to be produced by the assessee to substantiate its contention or what are the material or information to rebut the assessee’s explanation and evidences as discussed above. AO as well as the CIT(A) failed to appreciate or consider the more than sufficient evidences placed on record by the assessee to discharge the onus u/s 68 - Addition made u/s 68 of the Act is hereby deleted. - AT
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