Appeal dismissed: petitioner denied ITC for electricity used in township maintenance as residential supply; Explanation 1(d) prospective under s.2(17)...
Registration under section 12AA granted where substantive charitable objects for ex-servicemen, incidental commercial activity permitted and profits a...
ITAT upheld the addition of unexplained investment, holding that the assessee (anonymized) failed to substantiate the source of funds for acquisition of immovable property for A.Y. 2016-17. The Tribunal found the unregistered agreement to sell inconsistent with bank evidence, noting purported receipt of consideration at the agreement date conflicted with actual cheque payments in July 2015, undermining documentary credibility. Further, the existence of an earlier joint development agreement and a supplementary agreement demarcating shares meant the developer lacked a definite sellable area before April 2012, rendering alleged payments prior to that date unverifiable. Consequently the assessee's claim was rejected and the assessment sustained against the assessee.
ITAT upheld the addition of unexplained investment, holding that the assessee (anonymized) failed to substantiate the source of funds for acquisition of immovable property for A.Y. 2016-17. The Tribunal found the unregistered agreement to sell inconsistent with bank evidence, noting purported receipt of consideration at the agreement date conflicted with actual cheque payments in July 2015, undermining documentary credibility. Further, the existence of an earlier joint development agreement and a supplementary agreement demarcating shares meant the developer lacked a definite sellable area before April 2012, rendering alleged payments prior to that date unverifiable. Consequently the assessee's claim was rejected and the assessment sustained against the assessee.
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