Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
ITAT held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
ITAT held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
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