Revenue classification: agricultural land treated as capital asset under s.2(14)(iii)(b); consideration fixed at Rs.1,00,44,000; s.54F exemption allow...
ITAT held that additions and enhancements made by the AO and affirmed by the Ld. CIT(A) in respect of alleged undisclosed receipts and PoCM accruals are unsustainable. Diary entries seized from a director's premises partly related to a separate developer and, absent independent corroboration or statements enabling identification, cannot support additions founded on suspicion. The AO's 20% advance-based revenue recognition addition and enhancements premised on purported statements u/s 132(4) fail for lack of admissible corroborative material and absence of a show-cause opportunity as required by s. 251(2). The PoCM computations submitted by the assessee were not controverted; accordingly ITAT directed reversal of impugned additions and quashed the enhancements.
ITAT held that additions and enhancements made by the AO and affirmed by the Ld. CIT(A) in respect of alleged undisclosed receipts and PoCM accruals are unsustainable. Diary entries seized from a director's premises partly related to a separate developer and, absent independent corroboration or statements enabling identification, cannot support additions founded on suspicion. The AO's 20% advance-based revenue recognition addition and enhancements premised on purported statements u/s 132(4) fail for lack of admissible corroborative material and absence of a show-cause opportunity as required by s. 251(2). The PoCM computations submitted by the assessee were not controverted; accordingly ITAT directed reversal of impugned additions and quashed the enhancements.
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