Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
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Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
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