Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
ITAT directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
ITAT directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
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