Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Power of CIT(A) for enhancement u/s 251(2) - Enhancing the assessed income by making disallowances of deferred revenue expenses - There is no material on record suggesting that the assessee was awarded the opportunity of being heard before the enhancement of income by the learned CIT(A). As such, the appellate authority cannot enhance the assessment without issuing show cause notice. - AT
Power of CIT(A) for enhancement u/s 251(2) - Enhancing the assessed income by making disallowances of deferred revenue expenses - There is no material on record suggesting that the assessee was awarded the opportunity of being heard before the enhancement of income by the learned CIT(A). As such, the appellate authority cannot enhance the assessment without issuing show cause notice. - AT
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