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Third-party seized loose sheets can support an on-money addition only when corroborated or demonstrably connected to the assessee's business. Where flat-level particulars, cash receipts, the developer's role and offered profit established that connection, the Tribunal sustained the finding and quantification of on-money receipts, rejecting unsupported claims of duplicate entries, prior assessment and booking cancellations. As unaccounted real-estate receipts are business receipts, only their embedded profit is taxable; lacking a basis for a higher rate, the Tribunal reduced the estimated profit rate to 8 percent. No further telescoping was available because unaccounted expenditure had already been accepted as met from those receipts. Mere initiation of penalty proceedings was not appealable and the challenge was premature.
Third-party seized loose sheets can support an on-money addition only when corroborated or demonstrably connected to the assessee's business. Where flat-level particulars, cash receipts, the developer's role and offered profit established that connection, the Tribunal sustained the finding and quantification of on-money receipts, rejecting unsupported claims of duplicate entries, prior assessment and booking cancellations. As unaccounted real-estate receipts are business receipts, only their embedded profit is taxable; lacking a basis for a higher rate, the Tribunal reduced the estimated profit rate to 8 percent. No further telescoping was available because unaccounted expenditure had already been accepted as met from those receipts. Mere initiation of penalty proceedings was not appealable and the challenge was premature.
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