Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Reassessment was upheld because prior approval for the section 143(2) notice was found to have been communicated before issue, and the section 151 sanction and section 148B approval were not shown to suffer from non-application of mind. The Tribunal also held that seized books and digital cash ledgers found at third-party premises could be used where evidence showed group possession, control and participation in maintaining the records. On quantum, it rejected separate taxation of alleged on-money, V A/c and other entries on gross or estimated basis, holding that the seized material represented a single common cash pool and income had to be recomputed only on a unified year-wise peak credit basis in the assessee's hands.
Reassessment was upheld because prior approval for the section 143(2) notice was found to have been communicated before issue, and the section 151 sanction and section 148B approval were not shown to suffer from non-application of mind. The Tribunal also held that seized books and digital cash ledgers found at third-party premises could be used where evidence showed group possession, control and participation in maintaining the records. On quantum, it rejected separate taxation of alleged on-money, V A/c and other entries on gross or estimated basis, holding that the seized material represented a single common cash pool and income had to be recomputed only on a unified year-wise peak credit basis in the assessee's hands.
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