Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
Addition based on unsubstantiated documents like loose sheets, jottings, and Excel sheets - unaccounted cash receipts from students - cannot be sustained. Statements recorded solely cannot constitute incriminating material for additions. Unsubstantiated loose papers without corroboration by inquiry or leading to undisclosed assets cannot be basis for additions. Suspicion alone cannot replace evidence. AO failed to establish live link between seized material and unaccounted fees resulting in undisclosed assets. Uncorroborated seized material alone cannot be considered conclusive evidence. Presumption u/s 132(4) is rebuttable. AO should act judicially on adequate material, not arbitrarily. Additions cannot be made without examining concerned students/parents. Mere notes in diaries/loose sheets require corroboration. Non-speaking documents without corroborative evidence showing undisclosed income cannot be relied upon for additions.
Addition based on unsubstantiated documents like loose sheets, jottings, and Excel sheets - unaccounted cash receipts from students - cannot be sustained. Statements recorded solely cannot constitute incriminating material for additions. Unsubstantiated loose papers without corroboration by inquiry or leading to undisclosed assets cannot be basis for additions. Suspicion alone cannot replace evidence. AO failed to establish live link between seized material and unaccounted fees resulting in undisclosed assets. Uncorroborated seized material alone cannot be considered conclusive evidence. Presumption u/s 132(4) is rebuttable. AO should act judicially on adequate material, not arbitrarily. Additions cannot be made without examining concerned students/parents. Mere notes in diaries/loose sheets require corroboration. Non-speaking documents without corroborative evidence showing undisclosed income cannot be relied upon for additions.
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