Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
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