Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
An addition to taxable income based on an erroneous entry in the original tax-audit report was unsustainable where the assessee produced evidence of a substantially lower correct figure and the auditor subsequently revised and uploaded a corrected audit report; the appellate finding stressed that the evidentiary weight of an audit report is not absolute and must yield where a demonstrable clerical/figural error has been rectified, and that the first appellate authority's reliance on the uncorrected report was unreasonable. Operative effect: the addition set aside and the Assessing Officer directed to delete the disallowance for the relevant assessment year.
An addition to taxable income based on an erroneous entry in the original tax-audit report was unsustainable where the assessee produced evidence of a substantially lower correct figure and the auditor subsequently revised and uploaded a corrected audit report; the appellate finding stressed that the evidentiary weight of an audit report is not absolute and must yield where a demonstrable clerical/figural error has been rectified, and that the first appellate authority's reliance on the uncorrected report was unreasonable. Operative effect: the addition set aside and the Assessing Officer directed to delete the disallowance for the relevant assessment year.
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