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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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