Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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The ITAT held that additions based on loose papers/documents found during search at the assessee's premises without further corroboration would be contrary to judicial precedents. The circumstantial evidence did not contradict the assessee's assertions. Despite the search, no irregularities like excess cash or unaccounted assets were discovered. The adverse view by the AO and CIT(A) based solely on the loose papers appeared abstract without substantiation. The onus to prove the allegations lies with the Revenue, and the assessee cannot be burdened to prove a negative. Absence of supporting material, the assessee's denial, and their social status raised doubts favoring the assessee.
The ITAT held that additions based on loose papers/documents found during search at the assessee's premises without further corroboration would be contrary to judicial precedents. The circumstantial evidence did not contradict the assessee's assertions. Despite the search, no irregularities like excess cash or unaccounted assets were discovered. The adverse view by the AO and CIT(A) based solely on the loose papers appeared abstract without substantiation. The onus to prove the allegations lies with the Revenue, and the assessee cannot be burdened to prove a negative. Absence of supporting material, the assessee's denial, and their social status raised doubts favoring the assessee.
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