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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Additional evidence before the first appellate authority was held not to offend Rule 46A where the comparative cash-deposit chart was only a presentation derived from cash book and bank book already on record before the AO, so remand was unnecessary. On the merits, cash deposits made during demonetisation were accepted as explained because the assessee maintained audited books, showed cash balance and business cash flow, and the AO had not rejected the books or produced contrary evidence. The addition under section 69A was therefore unsustainable, and the Revenue's appeal was dismissed.
Additional evidence before the first appellate authority was held not to offend Rule 46A where the comparative cash-deposit chart was only a presentation derived from cash book and bank book already on record before the AO, so remand was unnecessary. On the merits, cash deposits made during demonetisation were accepted as explained because the assessee maintained audited books, showed cash balance and business cash flow, and the AO had not rejected the books or produced contrary evidence. The addition under section 69A was therefore unsustainable, and the Revenue's appeal was dismissed.
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