Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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