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Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Seized material showing unaccounted sales justified taxing only the profit embedded in the suppressed turnover, not the entire sale proceeds, and the addition had to be based on the actual sales figure found in the record rather than extrapolation. A separate addition for business expenditure under section 69C was deleted because the expenditure was sourced from the same unaccounted sales, and adding it again would amount to impermissible double addition. The Tribunal also upheld deletion of the alleged scrap sales addition on the factual finding that all scrap sales were recorded in the books, and rejected the Revenue's grievance on salary expenditure because no such addition had been made in the assessment order.
Seized material showing unaccounted sales justified taxing only the profit embedded in the suppressed turnover, not the entire sale proceeds, and the addition had to be based on the actual sales figure found in the record rather than extrapolation. A separate addition for business expenditure under section 69C was deleted because the expenditure was sourced from the same unaccounted sales, and adding it again would amount to impermissible double addition. The Tribunal also upheld deletion of the alleged scrap sales addition on the factual finding that all scrap sales were recorded in the books, and rejected the Revenue's grievance on salary expenditure because no such addition had been made in the assessment order.
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