Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Admission of additional evidence in appeal does not dispense with Rule 46A(3) compliance merely because the appellate authority invokes section 250(4). Where documents are produced for the first time in appeal and relied upon, the Assessing Officer must be confronted with them and given an opportunity to verify and comment. The Tribunal distinguished appellate enquiry powers from the separate procedure for admitting additional evidence, and held that they cannot be conflated to bypass the mandatory opportunity to the Assessing Officer. The deletion of the section 68 addition was therefore set aside on this limited ground, and the matter was remanded for fresh consideration after a remand report.
Admission of additional evidence in appeal does not dispense with Rule 46A(3) compliance merely because the appellate authority invokes section 250(4). Where documents are produced for the first time in appeal and relied upon, the Assessing Officer must be confronted with them and given an opportunity to verify and comment. The Tribunal distinguished appellate enquiry powers from the separate procedure for admitting additional evidence, and held that they cannot be conflated to bypass the mandatory opportunity to the Assessing Officer. The deletion of the section 68 addition was therefore set aside on this limited ground, and the matter was remanded for fresh consideration after a remand report.
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