Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
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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