Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
Reopening under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
Reopening under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
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