Search assessment additions require seized incriminating material, while unexplained land advances demand proof of payer identity and source.
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....Consequential assessments made under a subsisting revision order are tested against that order's directions and the action taken to implement them; an alleged defect in the original assessment alone does not invalidate the consequential assessment. For unabated search assessments, additions require incriminating material, which may comprise seized accounting data and corroborative statements rather than only the warrant or panchanama. Cash land advances remain unexplained credits where taxpayers do not establish payer identity, source, confirmations, or underlying transaction records; book entries and audited disclosures are insufficient against seized evidence of unaccounted cash. Telescoping against income offered by another group entity requires a proven factual nexus and assurance against double relief.....
TaxTMI