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ITAT upheld the CIT(A)'s relief largely in favour of the assessee: additions founded solely on WhatsApp messages and seized Excel records were deleted where evidence showed the assessee acted as consultant and was not owner, and where amounts appeared already taxed or attributable to third parties; unexplained expenditure under s.69C was deleted because seized documents disclosed the source; a 30% expense allocation on unaccounted receipts was accepted based on past financials and seized material; additions based solely on an exculpatory statement were deleted for lack of corroboration. However, the tribunal sustained the CIT(A)'s disallowance of rent under s.37(1) for want of documentary proof that the expenditure was wholly and exclusively for business.
ITAT upheld the CIT(A)'s relief largely in favour of the assessee: additions founded solely on WhatsApp messages and seized Excel records were deleted where evidence showed the assessee acted as consultant and was not owner, and where amounts appeared already taxed or attributable to third parties; unexplained expenditure under s.69C was deleted because seized documents disclosed the source; a 30% expense allocation on unaccounted receipts was accepted based on past financials and seized material; additions based solely on an exculpatory statement were deleted for lack of corroboration. However, the tribunal sustained the CIT(A)'s disallowance of rent under s.37(1) for want of documentary proof that the expenditure was wholly and exclusively for business.
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