Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
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Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
ITAT upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
ITAT upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
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