Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
ITAT notes that unaccounted sales should be taxed only to the extent of net profit embedded in those sales where seized material reflects both direct costs and indirect expenses; taxing the full gross profit element is excessive, and the rate in this matter was fixed at 2%. It also states that cash found during search can be telescoped against income already sustained on estimate where no separate use of that income elsewhere is shown, so a separate unexplained-money addition is deleted. Further, where profit estimation already subsumes the expenditure of the unaccounted activity, a separate addition for unexplained expenditure under section 69C would amount to double addition and should not survive.
ITAT notes that unaccounted sales should be taxed only to the extent of net profit embedded in those sales where seized material reflects both direct costs and indirect expenses; taxing the full gross profit element is excessive, and the rate in this matter was fixed at 2%. It also states that cash found during search can be telescoped against income already sustained on estimate where no separate use of that income elsewhere is shown, so a separate unexplained-money addition is deleted. Further, where profit estimation already subsumes the expenditure of the unaccounted activity, a separate addition for unexplained expenditure under section 69C would amount to double addition and should not survive.
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