Approvals under s.153D found mechanical and invalid; s.153A/s.153D assessments quashed; s.68 additions deleted where books rejected and s.144 best-jud...
HC dismissed the challenge to the ITAT's refusal to admit belated affidavits under Rule 29 of the ITAT Rules, 1963, holding that admission of additional evidence is permissible only where the assessee was prevented by the assessing authority from adducing it earlier. The court found the affidavits to be afterthoughts explaining unexplained income under s.69A and noted prior returns declared the amounts as income; one appellant had been set ex parte and an alleged third-party claim was never advanced at earlier stages. Rejection of the belated evidence was held justified and the ITAT's fact-based orders affirmed.
HC dismissed the challenge to the ITAT's refusal to admit belated affidavits under Rule 29 of the ITAT Rules, 1963, holding that admission of additional evidence is permissible only where the assessee was prevented by the assessing authority from adducing it earlier. The court found the affidavits to be afterthoughts explaining unexplained income under s.69A and noted prior returns declared the amounts as income; one appellant had been set ex parte and an alleged third-party claim was never advanced at earlier stages. Rejection of the belated evidence was held justified and the ITAT's fact-based orders affirmed.
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