Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
ITAT upholds the CIT(A) order in favour of the assessee and dismisses the Revenue's appeal. The Tribunal found that the AO, having himself made specific additions and disallowances after rejecting books, could not compel application of presumptive taxation under s.44AD; CIT(A)'s individual adjudication of each addition/disallowance is sustained. Deductions under ss.80HH/80I are allowed on the evidence furnished. Disallowances relating to manufacturing expenses, interest, unexplained investment in plant & machinery and many administrative/selling expenses are deleted or reduced (administrative/selling expenses restricted to one-tenth where appropriate). 100% depreciation on kegs is permitted. Grounds 1 and 2 of the Revenue are dismissed on merits.
ITAT upholds the CIT(A) order in favour of the assessee and dismisses the Revenue's appeal. The Tribunal found that the AO, having himself made specific additions and disallowances after rejecting books, could not compel application of presumptive taxation under s.44AD; CIT(A)'s individual adjudication of each addition/disallowance is sustained. Deductions under ss.80HH/80I are allowed on the evidence furnished. Disallowances relating to manufacturing expenses, interest, unexplained investment in plant & machinery and many administrative/selling expenses are deleted or reduced (administrative/selling expenses restricted to one-tenth where appropriate). 100% depreciation on kegs is permitted. Grounds 1 and 2 of the Revenue are dismissed on merits.
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