Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Penalty under s. 271AAB(1A)(b) was held unsustainable where the search did not unearth any incriminating material evidencing "undisclosed income" and the only basis was a statement under s. 132(4) offering additional income that was later retracted and was not reflected in the return for the relevant year. Since discovery of undisclosed income during or as a result of the search is a sine qua non for invoking s. 271AAB(1A)(b), a mere admission without corroborative seized material could not support penalty. Accordingly, deletion of the penalty was upheld and the revenue's appeal was dismissed. - ITAT
Penalty under s. 271AAB(1A)(b) was held unsustainable where the search did not unearth any incriminating material evidencing "undisclosed income" and the only basis was a statement under s. 132(4) offering additional income that was later retracted and was not reflected in the return for the relevant year. Since discovery of undisclosed income during or as a result of the search is a sine qua non for invoking s. 271AAB(1A)(b), a mere admission without corroborative seized material could not support penalty. Accordingly, deletion of the penalty was upheld and the revenue's appeal was dismissed. - ITAT
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