Reopening assessments beyond four years requires nondisclosure of material facts; mere change of opinion or general allegations invalidates reassessme...
Unexplained money under Section 69A was considered: Tribunal held that where amounts are withdrawn from disclosed bank accounts and the assessee furnishes books, vouchers and utilisation records which the Assessing Officer does not specifically discredit, the deeming provision cannot be invoked and addition is deleted. Separately, an ad hoc 5% disallowance of expenditure was set aside because, after remand production of cash books and supporting vouchers, no targeted rejection or cogent material demonstrated unverifiable or excessive expenditure, so blanket percentage disallowance was impermissible.
Unexplained money under Section 69A was considered: Tribunal held that where amounts are withdrawn from disclosed bank accounts and the assessee furnishes books, vouchers and utilisation records which the Assessing Officer does not specifically discredit, the deeming provision cannot be invoked and addition is deleted. Separately, an ad hoc 5% disallowance of expenditure was set aside because, after remand production of cash books and supporting vouchers, no targeted rejection or cogent material demonstrated unverifiable or excessive expenditure, so blanket percentage disallowance was impermissible.
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