Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
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Where an assessing officer treated an amount shown as outstanding in the assessee's balance-sheet as unexplained income, the Tribunal accepted that bank account statements and TDS challans (including TDS payment with interest and late fee) evidencing subsequent payment sufficiently established the outstanding liability; the sale deeds' recital of full receipt without recording mode of payment did not override documentary banking evidence. On that basis the Tribunal held the Section 69A addition unsustainable and deleted the addition, allowing the assessee's appeal for the relevant assessment year.
Where an assessing officer treated an amount shown as outstanding in the assessee's balance-sheet as unexplained income, the Tribunal accepted that bank account statements and TDS challans (including TDS payment with interest and late fee) evidencing subsequent payment sufficiently established the outstanding liability; the sale deeds' recital of full receipt without recording mode of payment did not override documentary banking evidence. On that basis the Tribunal held the Section 69A addition unsustainable and deleted the addition, allowing the assessee's appeal for the relevant assessment year.
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