Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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Whether additions for alleged contrived/fictitious NMCE commodity transactions were sustainable - held that the assessee had declared profits and furnished complete corroborative records (contract notes, broker ledgers, confirmations, bank statements, books) which matched NMCE data obtained u/s 133(6); AO did not identify any discrepancy nor produce independent evidence of fabrication, relying instead on general investigation inputs and selectively deeming parts of the same transactions non-genuine; conclusion: additions lacked factual and legal basis and were deleted. - ITAT
Whether additions for alleged contrived/fictitious NMCE commodity transactions were sustainable - held that the assessee had declared profits and furnished complete corroborative records (contract notes, broker ledgers, confirmations, bank statements, books) which matched NMCE data obtained u/s 133(6); AO did not identify any discrepancy nor produce independent evidence of fabrication, relying instead on general investigation inputs and selectively deeming parts of the same transactions non-genuine; conclusion: additions lacked factual and legal basis and were deleted. - ITAT
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