Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Addition u/s 69A - Source of Cash deposit - Assessee contended that same is received in advance against the sale of property - Levy of penalty u/s 271D - The ITAT held that, on one hand when the impugned cash receipts are characterized as assessee’s own money the same, on the other hand cannot be a specified sum received from someone else in contravention to provisions of section 269SS, therefore, the very foundation and prerequisite to bring such amount within the realm of section 269SS was lost. - Thus ITAT deleted the penalty on this ground. However, the lelvy penalty, on the issue of repayment of loan to financer in cash, got confirmed.
Addition u/s 69A - Source of Cash deposit - Assessee contended that same is received in advance against the sale of property - Levy of penalty u/s 271D - The ITAT held that, on one hand when the impugned cash receipts are characterized as assessee’s own money the same, on the other hand cannot be a specified sum received from someone else in contravention to provisions of section 269SS, therefore, the very foundation and prerequisite to bring such amount within the realm of section 269SS was lost. - Thus ITAT deleted the penalty on this ground. However, the lelvy penalty, on the issue of repayment of loan to financer in cash, got confirmed.
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