Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The ITAT ruled in favor of the assessee regarding additions made under section 153C based on entries in "Hazir Johri" software discovered during a search of JBL. While the AO relied on a director's statement confirming the software documented both official and unofficial transactions, the Tribunal found no concrete evidence linking the assessee to transactions in the combined ledger. The revenue failed to produce corroborative evidence such as bills, vouchers, or stock registers to establish the nature of transactions or prove cash sales belonged to the assessee. Following precedents in Anoop Kumar Soni and Surender Kumar Jain cases involving similar JBL search matters, the Tribunal concluded that entries in the software alone were insufficient for making additions.
The ITAT ruled in favor of the assessee regarding additions made under section 153C based on entries in "Hazir Johri" software discovered during a search of JBL. While the AO relied on a director's statement confirming the software documented both official and unofficial transactions, the Tribunal found no concrete evidence linking the assessee to transactions in the combined ledger. The revenue failed to produce corroborative evidence such as bills, vouchers, or stock registers to establish the nature of transactions or prove cash sales belonged to the assessee. Following precedents in Anoop Kumar Soni and Surender Kumar Jain cases involving similar JBL search matters, the Tribunal concluded that entries in the software alone were insufficient for making additions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
