Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
ITAT upheld the appellate authority's deletion of an addition under s.69A read with s.115BBE, concluding the assessee satisfactorily explained cash deposits (approx. Rs.39.84 crore) as receipts from its educational and medical activities and redeposits from bank withdrawals. The Tribunal found the AO made no cogent enquiry, did not reject the books of account, and the receipts were reflected in the assessee's gross receipts and audited accounts; consequently the impugned addition amounted to double taxation on disclosed receipts. ITAT refused remand, held the evidentiary materials placed before the AO had been duly considered by CIT(A), and affirmed deletion of the addition. Decision pronounced against the revenue.
ITAT upheld the appellate authority's deletion of an addition under s.69A read with s.115BBE, concluding the assessee satisfactorily explained cash deposits (approx. Rs.39.84 crore) as receipts from its educational and medical activities and redeposits from bank withdrawals. The Tribunal found the AO made no cogent enquiry, did not reject the books of account, and the receipts were reflected in the assessee's gross receipts and audited accounts; consequently the impugned addition amounted to double taxation on disclosed receipts. ITAT refused remand, held the evidentiary materials placed before the AO had been duly considered by CIT(A), and affirmed deletion of the addition. Decision pronounced against the revenue.
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