Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Seized electronic records found in a company's possession cannot, merely through rebuttable presumptions under sections 132(4A) and 292C, be treated as an individual manager's undisclosed income without independent proof of personal receipt, diversion, or beneficial enjoyment. The individual's substantive additions were therefore deleted. For the company, a worksheet showing unrecorded cash receipts and payments supported unaccounted cash movements but did not establish that all gross receipts were taxable income or fictitious expenditure. Without entity-wise attribution, identified fictitious claims, and evidence excluding cash circulation, only the unaccounted income element was estimated; substantive additions were confined to 25% of gross amounts.
Seized electronic records found in a company's possession cannot, merely through rebuttable presumptions under sections 132(4A) and 292C, be treated as an individual manager's undisclosed income without independent proof of personal receipt, diversion, or beneficial enjoyment. The individual's substantive additions were therefore deleted. For the company, a worksheet showing unrecorded cash receipts and payments supported unaccounted cash movements but did not establish that all gross receipts were taxable income or fictitious expenditure. Without entity-wise attribution, identified fictitious claims, and evidence excluding cash circulation, only the unaccounted income element was estimated; substantive additions were confined to 25% of gross amounts.
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TaxTMI 
TaxTMI 
of 4921 
