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ITAT remanded credit card payment assessment back to AO for detailed examination of salaried assessee's sources of funds. Tribunal emphasized necessity for thorough verification of bank statements and salary records before rejecting taxpayer's explanations regarding HDFC and ICICI credit card payments ranging from Rs.415 to Rs.35,000. On seized documents, ITAT deleted additions made under Section 292C, holding that AO failed to discharge onus of linking documents to assessee's undisclosed income. Tribunal noted that presumption under Section 292C is rebuttable, requiring corroborative evidence especially when assessee denies document knowledge. Notice under Section 143(2) was deemed unnecessary for Section 153A assessment following established precedent.
ITAT remanded credit card payment assessment back to AO for detailed examination of salaried assessee's sources of funds. Tribunal emphasized necessity for thorough verification of bank statements and salary records before rejecting taxpayer's explanations regarding HDFC and ICICI credit card payments ranging from Rs.415 to Rs.35,000. On seized documents, ITAT deleted additions made under Section 292C, holding that AO failed to discharge onus of linking documents to assessee's undisclosed income. Tribunal noted that presumption under Section 292C is rebuttable, requiring corroborative evidence especially when assessee denies document knowledge. Notice under Section 143(2) was deemed unnecessary for Section 153A assessment following established precedent.
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