Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
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The ITAT held that additions under section 69 for unexplained investments were not justified as the alleged investments were recorded in the books and the assessee provided satisfactory explanations supported by documentary evidence. The AO's reliance solely on account entries, prepared immediately after the financial year without corroborative proof, was insufficient. The tribunal emphasized that for invoking section 69, the investments must be unrecorded in the books and the source of funds unexplained. Here, the sale consideration was not paid, and there was no physical transfer of property, rendering the purported sale invalid and the deed ineffective. Consequently, no unexplained investment arose, and the addition under section 69 was unwarranted. The appeal was allowed, setting aside the addition.
The ITAT held that additions under section 69 for unexplained investments were not justified as the alleged investments were recorded in the books and the assessee provided satisfactory explanations supported by documentary evidence. The AO's reliance solely on account entries, prepared immediately after the financial year without corroborative proof, was insufficient. The tribunal emphasized that for invoking section 69, the investments must be unrecorded in the books and the source of funds unexplained. Here, the sale consideration was not paid, and there was no physical transfer of property, rendering the purported sale invalid and the deed ineffective. Consequently, no unexplained investment arose, and the addition under section 69 was unwarranted. The appeal was allowed, setting aside the addition.
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