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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
In the case, ITAT decided on two main issues: 1. Addition on account of Gold and Silver Jewellery u/s 69A: Assessee disclosed Rs. 70,00,000 as unexplained investment during search. ITAT found the disclosed gold and silver quantities reasonable based on CBDT guidelines. Assessee declared gold ornaments and silver items in HUF for deduction. ITAT directed AO to delete Rs. 28,96,104 addition. 2. Addition of cash found u/s 69A: Assessee explained Rs. 1,50,000 belonged to M/s. Sarvodaya Agrotech. AO added Rs. 3 lac cash found. CIT(A) sustained Rs. 2 lac addition, considering savings of Rs. 2 lac. ITAT found no merit in sustaining Rs. 2 lac addition, as assessee cooperated, disclosed income, and had wealth tax history. ITAT directed AO to delete the Rs. 2 lac cash addition.
In the case, ITAT decided on two main issues: 1. Addition on account of Gold and Silver Jewellery u/s 69A: Assessee disclosed Rs. 70,00,000 as unexplained investment during search. ITAT found the disclosed gold and silver quantities reasonable based on CBDT guidelines. Assessee declared gold ornaments and silver items in HUF for deduction. ITAT directed AO to delete Rs. 28,96,104 addition. 2. Addition of cash found u/s 69A: Assessee explained Rs. 1,50,000 belonged to M/s. Sarvodaya Agrotech. AO added Rs. 3 lac cash found. CIT(A) sustained Rs. 2 lac addition, considering savings of Rs. 2 lac. ITAT found no merit in sustaining Rs. 2 lac addition, as assessee cooperated, disclosed income, and had wealth tax history. ITAT directed AO to delete the Rs. 2 lac cash addition.
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