Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The ITAT held that the unexplained cash deposits in the assessee's bank account were attributable to the business of buying and selling mosquito nets, supported by purchase and sales records and bank statements. The Tribunal found that the CIT(A) erred in treating all credits as unexplained income under section 69A without considering the nature of the business. However, due to the absence of proper books of account, the Tribunal accepted an average net profit rate of 12% on the cash deposits, based on historical profit percentages from prior assessment years. Consequently, the addition of the entire amount as unexplained income was set aside, and only a proportionate addition reflecting 12% net profit was upheld, ensuring a fair and reasonable assessment in line with the principles of presumptive taxation.
The ITAT held that the unexplained cash deposits in the assessee's bank account were attributable to the business of buying and selling mosquito nets, supported by purchase and sales records and bank statements. The Tribunal found that the CIT(A) erred in treating all credits as unexplained income under section 69A without considering the nature of the business. However, due to the absence of proper books of account, the Tribunal accepted an average net profit rate of 12% on the cash deposits, based on historical profit percentages from prior assessment years. Consequently, the addition of the entire amount as unexplained income was set aside, and only a proportionate addition reflecting 12% net profit was upheld, ensuring a fair and reasonable assessment in line with the principles of presumptive taxation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
