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...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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In unabated assessments, additions under section 153A must rest on year-specific incriminating material; the Tribunal held that a loose sheet containing only rough notings, unrelated to the relevant assessment years, could not support presumed receipt of unaccounted cash from property sales, and the additions were deleted. It also held that section 69A could not apply where the assessee was not shown as buyer, seller, confirming party or beneficiary, and the receipts were plausibly explained as brokerage-related signatures without any corroborative evidence of ownership, possession or cash flow to the assessee. Both surviving additions were therefore unsustainable and were deleted.
In unabated assessments, additions under section 153A must rest on year-specific incriminating material; the Tribunal held that a loose sheet containing only rough notings, unrelated to the relevant assessment years, could not support presumed receipt of unaccounted cash from property sales, and the additions were deleted. It also held that section 69A could not apply where the assessee was not shown as buyer, seller, confirming party or beneficiary, and the receipts were plausibly explained as brokerage-related signatures without any corroborative evidence of ownership, possession or cash flow to the assessee. Both surviving additions were therefore unsustainable and were deleted.
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