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ITAT upheld the CIT(A)'s view and dismissed the Revenue's appeal: the profit on sale of a motor vehicle was not taxable as the motor car formed part of a continuing block of assets and the sale consideration was adjusted against the block; additions under section 69C for alleged unexplained import-related expenditure were deleted on documentary evidence; the tribunal directed complete deletion of the addition relating to writers' remuneration (modifying CIT(A)'s 10% disallowance) as surmise-based adjustments were impermissible; a 5% disallowance for transportation/distribution expenses was quashed; the section 143(2) notice was held invalid for non-compliance with CBDT instructions, rendering consequent proceedings void.
ITAT upheld the CIT(A)'s view and dismissed the Revenue's appeal: the profit on sale of a motor vehicle was not taxable as the motor car formed part of a continuing block of assets and the sale consideration was adjusted against the block; additions under section 69C for alleged unexplained import-related expenditure were deleted on documentary evidence; the tribunal directed complete deletion of the addition relating to writers' remuneration (modifying CIT(A)'s 10% disallowance) as surmise-based adjustments were impermissible; a 5% disallowance for transportation/distribution expenses was quashed; the section 143(2) notice was held invalid for non-compliance with CBDT instructions, rendering consequent proceedings void.
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