Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
WhatsApp chats alone cannot sustain an addition treating part of an agreed consideration as unexplained investment; corroboration in seized material and statements is required and lacking here, so the addition under section 69 read with section 115BBE was deleted. The statutory presumption in favour of documents found during search must be applied by reading seized documents and recorded statements collectively; a holistic appraisal of draft agreements, estimates, board resolution and statements supported the taxpayer's position that the alleged cash related to a proposed refurbishment not carried out or paid. The Revenue failed to discharge the burden to establish unexplained investment.
WhatsApp chats alone cannot sustain an addition treating part of an agreed consideration as unexplained investment; corroboration in seized material and statements is required and lacking here, so the addition under section 69 read with section 115BBE was deleted. The statutory presumption in favour of documents found during search must be applied by reading seized documents and recorded statements collectively; a holistic appraisal of draft agreements, estimates, board resolution and statements supported the taxpayer's position that the alleged cash related to a proposed refurbishment not carried out or paid. The Revenue failed to discharge the burden to establish unexplained investment.
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