Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
ITAT set aside CIT(A) order regarding cash deposits totaling Rs. 41,07,000 treated as unexplained under section 68. Assessee claimed deposits represented gifts from blood relations and agricultural income receipts but failed to provide strong arguments before lower authorities. However, ITAT accepted assessee's contention that addition should be restricted to peak credit of Rs. 15,27,000 rather than entire deposit amount. Matter remanded to AO for de-novo adjudication with directions to verify peak credit calculations and restrict addition accordingly after granting reasonable opportunity of hearing. AO instructed to examine supporting documentation and chart submitted by assessee demonstrating peak credit working. Appeal partly allowed for statistical purposes.
ITAT set aside CIT(A) order regarding cash deposits totaling Rs. 41,07,000 treated as unexplained under section 68. Assessee claimed deposits represented gifts from blood relations and agricultural income receipts but failed to provide strong arguments before lower authorities. However, ITAT accepted assessee's contention that addition should be restricted to peak credit of Rs. 15,27,000 rather than entire deposit amount. Matter remanded to AO for de-novo adjudication with directions to verify peak credit calculations and restrict addition accordingly after granting reasonable opportunity of hearing. AO instructed to examine supporting documentation and chart submitted by assessee demonstrating peak credit working. Appeal partly allowed for statistical purposes.
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