Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Addition u/s. 28(iv) - advance money against sale of property forfeited by the assessee - Merely for the reason that the amount received as loan in an earlier year was converted into advance payment for purchase of property, there is no reason to disbelieve the property transaction as a colourable device. No material has been brought to substantiate the above said view of the tax authorities, meaning thereby, they have entertained this view only on surmises and conjectures. - the provisions of section 51 of the Act shall be applicable and the above said amount would go to reduce the cost of property. - AT
Addition u/s. 28(iv) - advance money against sale of property forfeited by the assessee - Merely for the reason that the amount received as loan in an earlier year was converted into advance payment for purchase of property, there is no reason to disbelieve the property transaction as a colourable device. No material has been brought to substantiate the above said view of the tax authorities, meaning thereby, they have entertained this view only on surmises and conjectures. - the provisions of section 51 of the Act shall be applicable and the above said amount would go to reduce the cost of property. - AT
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