Case Law Analysis
|Income Tax Appellate Tribunal
Section 147 Income Tax Act | Revenue Must Prove Sale Transaction Beyond TDS Portal Data When Assessee Denies It : ITAT Delhi
When an assessee denies a sale transaction, the Income Tax Department cannot rely solely on TDS portal records to justify an addition under reassessment. ITAT Delhi holds that conclusive evidence - such as sale deeds, consideration flow, or third-party verification - is mandatory, reinforcing the principle that mere administrative data does not discharge the Revenue’s burden of proof.