Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Addition under section 40A(2)(b) challenged as based solely on a statement under section 132(4). The tribunal found the assessing officer relied on a misattributed statement (it belonged to a different declarant) and, following precedent that uncorroborated admissions during search cannot alone support assessments, held such statements do not justify additions absent independent evidence - consequence: the addition could not be sustained. Further, the recipient had declared the remuneration and comparative tax consequence showed no tax avoidance motive - consequence: deduction disallowed by AO was deleted and the appeal allowed. - ITAT
Addition under section 40A(2)(b) challenged as based solely on a statement under section 132(4). The tribunal found the assessing officer relied on a misattributed statement (it belonged to a different declarant) and, following precedent that uncorroborated admissions during search cannot alone support assessments, held such statements do not justify additions absent independent evidence - consequence: the addition could not be sustained. Further, the recipient had declared the remuneration and comparative tax consequence showed no tax avoidance motive - consequence: deduction disallowed by AO was deleted and the appeal allowed. - ITAT
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