Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
AT confirmed seized cash of Rs. 98.93 crores and 166.27 kg gold bullion as benami property under Section 2(9)(D) of PBPTA, overturning the Adjudicating Authority's decision. The Tribunal found the respondent firm's explanation regarding unrecorded sand sale proceeds unconvincing, particularly noting the timing of seizures post-demonetization and simultaneous filing of ITRs for two assessment years. Partners' contradictory statements and retractions undermined credibility. The substantial unaccounted assets, absence from regular books, and lack of proper business records indicated benami transactions where respondent merely lent their name while concealing actual beneficial owners. Appeal allowed, provisional attachment order upheld.
AT confirmed seized cash of Rs. 98.93 crores and 166.27 kg gold bullion as benami property under Section 2(9)(D) of PBPTA, overturning the Adjudicating Authority's decision. The Tribunal found the respondent firm's explanation regarding unrecorded sand sale proceeds unconvincing, particularly noting the timing of seizures post-demonetization and simultaneous filing of ITRs for two assessment years. Partners' contradictory statements and retractions undermined credibility. The substantial unaccounted assets, absence from regular books, and lack of proper business records indicated benami transactions where respondent merely lent their name while concealing actual beneficial owners. Appeal allowed, provisional attachment order upheld.
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