Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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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