Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Whether addition under s.69 for alleged cash "on-money" paid for purchase of a shop could be sustained merely on statements recorded during search and an Excel sheet found in a third party's pen drive. The material on record, including allotment letter and bank statements, showed no evidence of any cash payment in AYs 2017-18 and 2018-19 and indicated that the purchase transaction occurred only in AY 2019-20; hence the s.69 additions for AYs 2017-18 and 2018-19 were deleted. For AY 2019-20, the statements and Excel sheet were held uncorroborated by independent evidence, consistent with co-ordinate bench precedents; hence the s.69 addition was deleted and the appeals were allowed - ITAT
Whether addition under s.69 for alleged cash "on-money" paid for purchase of a shop could be sustained merely on statements recorded during search and an Excel sheet found in a third party's pen drive. The material on record, including allotment letter and bank statements, showed no evidence of any cash payment in AYs 2017-18 and 2018-19 and indicated that the purchase transaction occurred only in AY 2019-20; hence the s.69 additions for AYs 2017-18 and 2018-19 were deleted. For AY 2019-20, the statements and Excel sheet were held uncorroborated by independent evidence, consistent with co-ordinate bench precedents; hence the s.69 addition was deleted and the appeals were allowed - ITAT
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