Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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Loose papers that are undated, unsigned and unlinked to the assessee cannot, by themselves, support additions for unexplained investment under section 69; the Tribunal treated the paper as a dumb document and deleted the addition. A figure on the same paper also could not be taxed as unexplained money under section 69A because no money or other valuable asset was found in the assessee's ownership, and the nature of the entry was not established; that addition was deleted. A gross profit addition based only on alleged stock shortage was rejected because the assessee gave a plausible job-work explanation that was not disproved. Third-party WhatsApp and police material could not be used without full disclosure or cross-examination, so the betting-related section 69A addition also failed.
Loose papers that are undated, unsigned and unlinked to the assessee cannot, by themselves, support additions for unexplained investment under section 69; the Tribunal treated the paper as a dumb document and deleted the addition. A figure on the same paper also could not be taxed as unexplained money under section 69A because no money or other valuable asset was found in the assessee's ownership, and the nature of the entry was not established; that addition was deleted. A gross profit addition based only on alleged stock shortage was rejected because the assessee gave a plausible job-work explanation that was not disproved. Third-party WhatsApp and police material could not be used without full disclosure or cross-examination, so the betting-related section 69A addition also failed.
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