Documentary evidence reliability: unauthenticated marketing sheets and portal rates cannot sustain sales suppression additions, deletions ordered.
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....Seized marketing 'welcome letters' and loose undated digital sheets were held insufficiently reliable to support additions for alleged suppression of sales absent signatures, buyer confirmations, bank-trace or other corroboration; extrapolation of undeclared sales by applying unauthenticated online portal asking rates was held speculative and inadmissible without seized evidence, buyer examination, comparable deeds or valuation; for unexplained cash credits the assessee discharged primary onus by producing identity, ledger entries, bank records and lender financials and repayments, and the AO failed to rebut with cogent material; approval by the range head for assessment proceedings was found to be non-mechanical. Operative effect: document-based and extrapolated additions and unexplained-loan additions were deleted, while approval validity was upheld.....
TaxTMI