Just a moment...

Top
Help
AI Drafter

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

Try Now
×

By creating an account you can:

Logo TaxTMI
>
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
TMI Blog
Home / RSS

Addition for alleged unexplained investment under Section 69 deleted due to coerced agreement and lack of corroboration

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....HC upheld the deletion of addition u/s 69 made on the basis of a notarized agreement recovered during survey proceedings. The AO/DDIT had relied solely on the agreement, without issuing summons to the third party or conducting independent investigation to verify its contents or to establish any actual flow of funds. CIT(A) and the Tribunal found that the assessee had, prior to the survey, lodged complaints before the PMO and Home Ministry alleging coercion in signing the agreement, reinforcing the claim that the document was not voluntary. In absence of corroborative evidence such as bank transactions or other material linking the assessee to unexplained investment, the addition was held unsustainable. HC concluded that the concurrent findings of CIT(A) and Tribunal were factual and reasonable, and that no substantial question of law arose, thereby dismissing the revenue's appeal.....