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Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
The HC upheld the Tribunal's enhancement of the addition for unaccounted on-money received by the appellant-assessee, as discovered during a search under section 132(1). The Tribunal's estimate of 10% on total booking receipts was based on the voluntary statement of the Director and corroborated by the actual cash found. The Tribunal's order merely adjusted the quantum of on-money previously sustained in part by the CIT (Appeals), applying the 10% rate across all projects, including the 'Sarjan' flats. The concurrent findings of fact by the CIT (Appeals) and the Tribunal regarding the receipt of on-money were affirmed, and no substantial question of law arose. The decision was rendered in favor of the revenue, confirming the validity of the enhanced addition on the basis of accepted factual findings.
The HC upheld the Tribunal's enhancement of the addition for unaccounted on-money received by the appellant-assessee, as discovered during a search under section 132(1). The Tribunal's estimate of 10% on total booking receipts was based on the voluntary statement of the Director and corroborated by the actual cash found. The Tribunal's order merely adjusted the quantum of on-money previously sustained in part by the CIT (Appeals), applying the 10% rate across all projects, including the 'Sarjan' flats. The concurrent findings of fact by the CIT (Appeals) and the Tribunal regarding the receipt of on-money were affirmed, and no substantial question of law arose. The decision was rendered in favor of the revenue, confirming the validity of the enhanced addition on the basis of accepted factual findings.
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