Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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CBDT Instruction No. 1916, though framed for non-seizure of jewellery during search, was treated as a relevant guideline recognising customary family holdings of jewellery. The Tribunal accepted that jewellery within the prescribed limits could not be regarded as unexplained investment merely because it was found during search, especially where the assessee furnished explanations supported by family holdings, a wealth-tax disclosure for the HUF, purchase bills, and statements recorded during search and assessment. On that basis, the addition under unexplained investment was directed to be deleted to the extent covered by the instruction.
CBDT Instruction No. 1916, though framed for non-seizure of jewellery during search, was treated as a relevant guideline recognising customary family holdings of jewellery. The Tribunal accepted that jewellery within the prescribed limits could not be regarded as unexplained investment merely because it was found during search, especially where the assessee furnished explanations supported by family holdings, a wealth-tax disclosure for the HUF, purchase bills, and statements recorded during search and assessment. On that basis, the addition under unexplained investment was directed to be deleted to the extent covered by the instruction.
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