Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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