Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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.
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