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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...
Addition under section 69A was sustained where the assessee's statement under section 132(4) was linked to seized material and not rebutted by credible evidence. The Tribunal found this was not a bare confession: the seized document recovered during search provided the incriminating basis, the assessee gave a detailed explanation of the cash loan, source, interest arrangement and proposed recovery, and the statement was not retracted for a long period. The later claim that the figure represented cheque recoveries was held inconsistent with the ledger account, which showed no outstanding receivable on the date of search. The addition was therefore upheld and the appeal dismissed.
Addition under section 69A was sustained where the assessee's statement under section 132(4) was linked to seized material and not rebutted by credible evidence. The Tribunal found this was not a bare confession: the seized document recovered during search provided the incriminating basis, the assessee gave a detailed explanation of the cash loan, source, interest arrangement and proposed recovery, and the statement was not retracted for a long period. The later claim that the figure represented cheque recoveries was held inconsistent with the ledger account, which showed no outstanding receivable on the date of search. The addition was therefore upheld and the appeal dismissed.
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