Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
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