Promissory note presumption of consideration survives blank-signature and income-tax non-disclosure objections when admissions and attesting evidence ...
Charitable registration cancellation: limitation and jurisdiction upheld, but withdrawal quashed under discontinued provisions for skill-development e...
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The ITAT upheld reassessment jurisdiction under the post-1.4.2021 search regime, holding that incriminating material is not a condition precedent for issuing notice under section 148 and that such material is to be examined in the reassessment proceedings; the challenge to the notice therefore failed. On merits, it deleted the section 68 and consequential section 69C additions on sale of investments, finding that the investments were earlier accepted in audited balance sheets and scrutiny, sale proceeds were received through banking channels from identified purchasers, and the additions rested mainly on uncorroborated third-party statements and seized material without cross-examination.
The ITAT upheld reassessment jurisdiction under the post-1.4.2021 search regime, holding that incriminating material is not a condition precedent for issuing notice under section 148 and that such material is to be examined in the reassessment proceedings; the challenge to the notice therefore failed. On merits, it deleted the section 68 and consequential section 69C additions on sale of investments, finding that the investments were earlier accepted in audited balance sheets and scrutiny, sale proceeds were received through banking channels from identified purchasers, and the additions rested mainly on uncorroborated third-party statements and seized material without cross-examination.
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