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of <h1>Deeming unexplained expenditure as income without safeguards exposes taxpayers to compliance, recordkeeping and assessment risks</h1> Two near-identical provisions deem expenditure unexplained and treat it as the assessee's income if no explanation is offered or the Assessing Officer finds the explanation unsatisfactory, and bar any deduction for that amount. The enacted Act expressly confines the officer's satisfaction inquiry to the source of expenditure, narrowing the Bill's broader phrasing that could encompass any aspect of an explanation. Both versions delegate evaluative power to the Assessing Officer, contain no definitions, thresholds, procedural safeguards, evidentiary standards, burden-of-proof allocation, or appeal/useful guidance, and include a non-obstante clause prioritizing the deeming over other deduction provisions. Taxpayers therefore face compliance and recordkeeping risks.
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