Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
AT dismissed the appeal and upheld the provisional attachment order. The Tribunal found that the appellant failed to satisfactorily disclose the source of funds used to acquire the disputed property, including unexplained receipts aggregating Rs. 12 crore routed through intermediary entities and paid to a vendor's employee, and that documentary proof for asserted loans was not produced. The AT held that record-level statements sufficiently establish proceeds of crime and that Section 8(1) requires satisfaction on notice regarding source. The Tribunal endorsed attachment of property of equivalent value where original proceeds are unavailable and rejected mala fides/political vendetta allegations for lack of proof. The appeal therefore fails on all grounds.
AT dismissed the appeal and upheld the provisional attachment order. The Tribunal found that the appellant failed to satisfactorily disclose the source of funds used to acquire the disputed property, including unexplained receipts aggregating Rs. 12 crore routed through intermediary entities and paid to a vendor's employee, and that documentary proof for asserted loans was not produced. The AT held that record-level statements sufficiently establish proceeds of crime and that Section 8(1) requires satisfaction on notice regarding source. The Tribunal endorsed attachment of property of equivalent value where original proceeds are unavailable and rejected mala fides/political vendetta allegations for lack of proof. The appeal therefore fails on all grounds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
