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HC dismissed the assessee's challenge to the revisional order u/s 264, upholding characterization of the disclosed sums as unexplained money u/s 69A, noting absence of ITRs for AYs 2014-15 and 2015-16, failure to explain source of income, and minimal compliance with notices u/s 142(1). The HC held the revisional authority's view to be a plausible one warranting no interference under Art. 226. However, following precedent, HC held that partial payments made under IDS, 2016 could not be retained by Revenue without authority of law and directed that credit be given for such installments (or adjustment under other schemes) in accordance with constitutional and statutory requirements.
HC dismissed the assessee's challenge to the revisional order u/s 264, upholding characterization of the disclosed sums as unexplained money u/s 69A, noting absence of ITRs for AYs 2014-15 and 2015-16, failure to explain source of income, and minimal compliance with notices u/s 142(1). The HC held the revisional authority's view to be a plausible one warranting no interference under Art. 226. However, following precedent, HC held that partial payments made under IDS, 2016 could not be retained by Revenue without authority of law and directed that credit be given for such installments (or adjustment under other schemes) in accordance with constitutional and statutory requirements.
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