Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Treatment of a negative cash balance as income from unexplained sources was upheld because the taxpayer failed to prove that alleged cash gifts had a verifiable donor source. The court applied the principle that cash gifts require independent evidence of the donor's capacity and source of funds; self signed receipts and a post hoc declaration were insufficient. Inconsistent statements about the donor and absence of the donor's tax filings or other corroboration undermined credibility, leading to rejection of the gift claim and endorsement of the unexplained cash balance being taxed as income.
Treatment of a negative cash balance as income from unexplained sources was upheld because the taxpayer failed to prove that alleged cash gifts had a verifiable donor source. The court applied the principle that cash gifts require independent evidence of the donor's capacity and source of funds; self signed receipts and a post hoc declaration were insufficient. Inconsistent statements about the donor and absence of the donor's tax filings or other corroboration undermined credibility, leading to rejection of the gift claim and endorsement of the unexplained cash balance being taxed as income.
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