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ITAT addressed three key issues in this tax appeal. The tribunal upheld the addition of undisclosed income based on electronic evidence from a seized pen drive, as proper certification under Section 65B(4) of Indian Evidence Act was obtained. Regarding unaccounted cash receipts, ITAT modified CIT(A)'s approach of applying 85% blanket rate, directing reassessment based on the assessee's declared net profit rates for respective years. On R&D deductions under Section 35(2AB), the tribunal confirmed that post July 2016, deductions must align with DSIR quantification, except for AY 2016-17 where full revenue expenditure deduction was allowed. The tribunal also upheld CIT(A)'s deletion of Section 69C additions after verifying opening cash balances from seized documents.
ITAT addressed three key issues in this tax appeal. The tribunal upheld the addition of undisclosed income based on electronic evidence from a seized pen drive, as proper certification under Section 65B(4) of Indian Evidence Act was obtained. Regarding unaccounted cash receipts, ITAT modified CIT(A)'s approach of applying 85% blanket rate, directing reassessment based on the assessee's declared net profit rates for respective years. On R&D deductions under Section 35(2AB), the tribunal confirmed that post July 2016, deductions must align with DSIR quantification, except for AY 2016-17 where full revenue expenditure deduction was allowed. The tribunal also upheld CIT(A)'s deletion of Section 69C additions after verifying opening cash balances from seized documents.
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