Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
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