Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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The ITAT set aside the addition under section 69A read with section 115BBE relating to undisclosed investment of Rs. 50 lakhs. The AO failed to produce any material evidence or documentation proving that the assessee owned the cash or had made the alleged payment to the third party for the purchase of immovable property. The denial by the alleged payee remained unchallenged and the mere WhatsApp communication with a third party, not involved in the original transaction, was held insufficient to establish ownership or cash transaction. Consequently, invocation of section 69A was unwarranted for the assessment year 2022-23. The Tribunal deleted the addition and allowed the assessee's appeal.
The ITAT set aside the addition under section 69A read with section 115BBE relating to undisclosed investment of Rs. 50 lakhs. The AO failed to produce any material evidence or documentation proving that the assessee owned the cash or had made the alleged payment to the third party for the purchase of immovable property. The denial by the alleged payee remained unchallenged and the mere WhatsApp communication with a third party, not involved in the original transaction, was held insufficient to establish ownership or cash transaction. Consequently, invocation of section 69A was unwarranted for the assessment year 2022-23. The Tribunal deleted the addition and allowed the assessee's appeal.
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