Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
ITAT held that additions based solely on third party digital material (pen drive/excel files) and statements, without cash vouchers, receipts or documents linking the assessee, required independent corroboration by the Revenue and an opportunity for the assessee to confront or cross examine deponents; the Assessing Officer failed to produce corroborative evidence or comparable transactions and denied confrontation, breaching principles of natural justice. Consequently the Tribunal found the additions unsustainable and deleted them, allowing the appeals for the relevant assessment years.
ITAT held that additions based solely on third party digital material (pen drive/excel files) and statements, without cash vouchers, receipts or documents linking the assessee, required independent corroboration by the Revenue and an opportunity for the assessee to confront or cross examine deponents; the Assessing Officer failed to produce corroborative evidence or comparable transactions and denied confrontation, breaching principles of natural justice. Consequently the Tribunal found the additions unsustainable and deleted them, allowing the appeals for the relevant assessment years.
Note: It is a system-generated summary and is for quick reference only.