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ITAT ruled in favor of the assessee regarding disputed cash deposits and property investments made through NRE account. The tribunal rejected revenue authorities' contentions about unexplained sources of 50,000 USD cash deposit, finding sufficient documentary evidence proving withdrawal from South African company SPPL where assessee's spouse was director. ITAT dismissed DRP's reasoning that physical transport of dollars was suspicious as irrelevant to transaction legitimacy. Similarly, property investment sourced from foreign entity and registration charges funded by assessee's son through documented transfers were deemed adequately explained. The tribunal emphasized that transactions through NRE account, supported by evidence of foreign source funds from companies where assessee/spouse held positions or family member advances, satisfied burden of proof for transaction genuineness.
ITAT ruled in favor of the assessee regarding disputed cash deposits and property investments made through NRE account. The tribunal rejected revenue authorities' contentions about unexplained sources of 50,000 USD cash deposit, finding sufficient documentary evidence proving withdrawal from South African company SPPL where assessee's spouse was director. ITAT dismissed DRP's reasoning that physical transport of dollars was suspicious as irrelevant to transaction legitimacy. Similarly, property investment sourced from foreign entity and registration charges funded by assessee's son through documented transfers were deemed adequately explained. The tribunal emphasized that transactions through NRE account, supported by evidence of foreign source funds from companies where assessee/spouse held positions or family member advances, satisfied burden of proof for transaction genuineness.
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