Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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ITAT upheld the AO's addition under Section 69 as unexplained investment, rejecting the assessee's contentions. The tribunal found that the seized incriminating material carried a presumption of correctness under Section 292C of the Income Tax Act. The proceedings were governed by preponderance of probability, not criminal standard of proof beyond reasonable doubt. The assessee's arguments regarding criminal court proceedings and natural justice were dismissed. The tribunal emphasized that the Income Tax Act is a complete code, and the department's findings were based on conclusive evidence. The impugned additions for multiple assessment years were sustained, with the decision rendered in favor of the revenue.
ITAT upheld the AO's addition under Section 69 as unexplained investment, rejecting the assessee's contentions. The tribunal found that the seized incriminating material carried a presumption of correctness under Section 292C of the Income Tax Act. The proceedings were governed by preponderance of probability, not criminal standard of proof beyond reasonable doubt. The assessee's arguments regarding criminal court proceedings and natural justice were dismissed. The tribunal emphasized that the Income Tax Act is a complete code, and the department's findings were based on conclusive evidence. The impugned additions for multiple assessment years were sustained, with the decision rendered in favor of the revenue.
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