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...
Addition based on undisclosed income allegedly admitted during survey u/s 133A was deleted because the Revenue produced no substantive corroborative evidence, and a survey statement, particularly when promptly retracted and alleged to be obtained under coercion, lacks evidentiary value; reliance was placed on binding precedent holding that no addition can rest solely on such statement, supported by CBDT instructions to rely on material evidence, resulting in dismissal of the Revenue's ground. Disallowance u/s 40A(3) was upheld only to the extent sustained by the first appellate authority since detailed expense-wise verification showed certain payments were made through account payee cheque and the appellate findings disclosed no infirmity, leading to rejection of the Revenue's challenge. - ITAT
Addition based on undisclosed income allegedly admitted during survey u/s 133A was deleted because the Revenue produced no substantive corroborative evidence, and a survey statement, particularly when promptly retracted and alleged to be obtained under coercion, lacks evidentiary value; reliance was placed on binding precedent holding that no addition can rest solely on such statement, supported by CBDT instructions to rely on material evidence, resulting in dismissal of the Revenue's ground. Disallowance u/s 40A(3) was upheld only to the extent sustained by the first appellate authority since detailed expense-wise verification showed certain payments were made through account payee cheque and the appellate findings disclosed no infirmity, leading to rejection of the Revenue's challenge. - ITAT
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