Cash routed to non-existent firm deemed proceeds of crime; laundered funds and properties attachable, provisional attachments confirmed; two accounts ...
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Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
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