Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Addition under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
Addition under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
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