Appeal allowed; impugned order quashed as regulator failed to prove nexus or manipulative scheme; sale genuine - s.12A(a)-(c), Regs 3(a)-(d),4(1),4(2)...
Appellant's ring-back tone service held OIDAR, taxable domestically for 01.07.2012-31.07.2016; liability confirmed, penalties vacated, remanded for re...
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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