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The ITAT adjudicated a tax dispute involving unaccounted receipts and expenses in business transactions. The tribunal held that seized materials must be read holistically, rejecting the Assessing Officer's selective approach. Applying the principle of not simultaneously taxing income source and application, the tribunal directed adoption of a 13% profit margin instead of 14%. For completed assessments without incriminating materials during search proceedings, the tribunal followed Supreme Court precedent and deleted additions made by the Assessing Officer. Consequently, the assessee's appeal was allowed, with the jurisdictional officer instructed to recalculate tax liability based on the 13% profit margin and holistic assessment of unaccounted transactions.
The ITAT adjudicated a tax dispute involving unaccounted receipts and expenses in business transactions. The tribunal held that seized materials must be read holistically, rejecting the Assessing Officer's selective approach. Applying the principle of not simultaneously taxing income source and application, the tribunal directed adoption of a 13% profit margin instead of 14%. For completed assessments without incriminating materials during search proceedings, the tribunal followed Supreme Court precedent and deleted additions made by the Assessing Officer. Consequently, the assessee's appeal was allowed, with the jurisdictional officer instructed to recalculate tax liability based on the 13% profit margin and holistic assessment of unaccounted transactions.
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