Search assessment and multiplex lease receipts: incriminating material limits additions, but commercial exploitation supported business income treatme...
The High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
The High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
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