Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
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