Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
ITAT upheld the CIT(A)'s deletion of additions u/s 68 and 69A made on the basis of a seized day-cash-book/diary belonging to a third-party group. It held that unilateral decoding of notings by the AO, without examining the author or any connected person and without corroboration from bank records, audited books, confirmations or other primary evidence, lacked evidentiary value. As the loose sheets neither named the assessee nor established a one-to-one nexus with recorded cheque transactions, they were treated as "dumb documents." Additions based on such unverified third-party loose papers were held unsustainable, and the appeals were decided in favour of the assessee.
ITAT upheld the CIT(A)'s deletion of additions u/s 68 and 69A made on the basis of a seized day-cash-book/diary belonging to a third-party group. It held that unilateral decoding of notings by the AO, without examining the author or any connected person and without corroboration from bank records, audited books, confirmations or other primary evidence, lacked evidentiary value. As the loose sheets neither named the assessee nor established a one-to-one nexus with recorded cheque transactions, they were treated as "dumb documents." Additions based on such unverified third-party loose papers were held unsustainable, and the appeals were decided in favour of the assessee.
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