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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT upheld addition under section 68 for unexplained cash credit based on seized receipt dated 13.05.2008 acknowledging "on money" of Rs. 4.25 crores. Twin assessees challenged addition claiming receipt was undated and no amount received. Tribunal rejected contentions, applying section 292C statutory presumption regarding seized documents' correctness. However, ITAT reduced total addition from Rs. 5.25 crores to Rs. 4.25 crores as per receipt amount, rejecting revenue's extrapolation. Addition apportioned equally between assessees at 50% each. CIT(A)'s restriction to Rs. 1,09,89,285 was overturned. Tribunal distinguished Bharat Engineering precedent regarding first-year business additions, noting complex web of group entity transactions. Appeals partially allowed with addition confirmed at Rs. 4.25 crores total.
ITAT upheld addition under section 68 for unexplained cash credit based on seized receipt dated 13.05.2008 acknowledging "on money" of Rs. 4.25 crores. Twin assessees challenged addition claiming receipt was undated and no amount received. Tribunal rejected contentions, applying section 292C statutory presumption regarding seized documents' correctness. However, ITAT reduced total addition from Rs. 5.25 crores to Rs. 4.25 crores as per receipt amount, rejecting revenue's extrapolation. Addition apportioned equally between assessees at 50% each. CIT(A)'s restriction to Rs. 1,09,89,285 was overturned. Tribunal distinguished Bharat Engineering precedent regarding first-year business additions, noting complex web of group entity transactions. Appeals partially allowed with addition confirmed at Rs. 4.25 crores total.
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