Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
The article addresses the legal infirmity of tax additions founded solely on digital ledger entries seized from a third party (Hazir Johri software). It states the statutory presumption applicable to a searched person does not extend to third parties (JBL), and ledger entries without contemporaneous corroboration (bills, invoices, vouchers, stock records) or exclusive linkage to the assessee are insufficient to sustain assessments. Applying this principle, peak credit and deemed unexplained money/profit additions based on such third party software entries and an employee statement were treated as conjectural and deleted; the appeals were allowed for the relevant years.
The article addresses the legal infirmity of tax additions founded solely on digital ledger entries seized from a third party (Hazir Johri software). It states the statutory presumption applicable to a searched person does not extend to third parties (JBL), and ledger entries without contemporaneous corroboration (bills, invoices, vouchers, stock records) or exclusive linkage to the assessee are insufficient to sustain assessments. Applying this principle, peak credit and deemed unexplained money/profit additions based on such third party software entries and an employee statement were treated as conjectural and deleted; the appeals were allowed for the relevant years.
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