Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Where seized diary and pen-drive material belonged to a third party, the rebuttable presumptions under sections 132(4A) and 292C did not apply against the assessee, so the Revenue had to produce independent corroborative evidence of actual cash receipts. As the loose sheets were not in the assessee's handwriting or signed by it, nothing was found from its premises, and the third party's retracted employee statements were not conclusive, the alleged cash receipts and the resulting profit estimation were deleted. On the alleged on-money entry, the Tribunal found no nexus between the seized material and any cash payment, and held the inference to be mere guesswork; that addition was also deleted.
Where seized diary and pen-drive material belonged to a third party, the rebuttable presumptions under sections 132(4A) and 292C did not apply against the assessee, so the Revenue had to produce independent corroborative evidence of actual cash receipts. As the loose sheets were not in the assessee's handwriting or signed by it, nothing was found from its premises, and the third party's retracted employee statements were not conclusive, the alleged cash receipts and the resulting profit estimation were deleted. On the alleged on-money entry, the Tribunal found no nexus between the seized material and any cash payment, and held the inference to be mere guesswork; that addition was also deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
