S. 69 : Unexplained investments-Addition at rate of 4% assuming saving bank account interest rate earned on bank balances with HSBC, Geneva-Illogical to compute interest rate prevailing in India as there was no documentary evidence to support presumption of AO-Same amount taxed twice in two assessment years amounts to double taxation deleted addition. [S. 153A]
S. 69 : Unexplained investments-Bank deposit-Non-Resident-Two bank accounts in HSBC Geneva-Non-Resident-Income earned in Abu Dhabi and savings made in UAE as a non-resident-Addition cannot be made merely on the basis of information received from DIT. [S. 147]
S. 68 : Cash credit-Income from undisclosed sources-Bank statement of assessee showing loan from non-resident individual-During appeal proceedings filing confirmation of lender with his passport, copy of bank account and affidavit of seller-Addition not justified.[S. 69]
S. 68 : Cash Credits-Gift from father-Addition is held to be not justified.
S. 68 : Cash credits-Share Application Money-Shares issued at premium-Identity of parties, genuineness of transactions and creditworthiness proved-Additions cannot be made merely on the basis of inferences. [S. 131(1)(d)]
S. 68 : Cash credits-Share Application Money-Shares issued at premium-Identity of parties, genuineness of transactions and creditworthiness proved-Additions cannot be made merely on the basis of inferences. [S. 131(1)(d)]
S. 68 : Cash credits-Share application money-Notice issued to share applicants u/s 133(6) of the Act-Matter remanded. [S. 133(6)]
S. 68 : Cash credits-Share application money-Notice issued to share applicants u/s 133(6) of the Act-Matter remanded. [S. 133(6)]
S. 68 : Cash credits-Income from undisclosed sources-Non-Resident-Balance in bank accounts abroad-HSBC in Geneva-Addition as peak addition is held to be not valid [S. 5(2), 69]
S. 68 : Cash credits-Share capital-Share premium-Denial of opportunity to cross-examine witness-Principle of natural justice is violated-Entire addition solely on the basis of statement is deleted-The assessee has discharged by furnishing copes of PAN memorandum of association bank account details etc-Order of CIT(A) deleting the addition was affirmed. [S. 131]