3 Review(s)

The Supreme Court confirmed that demonetisation-era cash deposits can be added as unexplained income under Section 69A if the assessee fails to satisfactorily explain their source. The decision reinforces a strict approach on undisclosed cash, shifting the burden squarely onto taxpayers.The Court held that unexplained credits routed through intermediary (conduit) companies are taxable in the hands of ultimate beneficiaries. This prevents taxpayers from masking income by using layered structures.On a reference under Indo‑Swiss DTAA, the Delhi Court ruled that assessment under Section 153B must comply with DTAA timelines— Revenue cannot evade the one‑year limitation without proper reference.Notices issued between 1 Apr–30 Jun 2021 under old Section 148 are treated as valid under Section 148A(b) (post‑2021 amendments), provided proper material is served and the procedure followed. This restored validity to many pending reassessments The Court held that Variable Licence Fees (VLF) paid by telecom operators to the Government are capital expenditures—not revenue ones. This preserves the Revenue’s position to charge depreciation and correct classification of expenses.