Revenue Must Prove Actual Sales in Seized Diary u/ss 153C and 69A; Presumptions Insufficient.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Assessment u/s 153C - Unexplained cash receipt u/s 69A - The onus was on revenue to prove with corroborative evidence that the entries in the seized dairy actually represented the sales made by the assessee. Mere entries in the seized material was not sufficient to prove that the assessee has indulged in such a transaction - additions based on mere presumptions and assumptions and without any corroborative evidence could not be sustained.....