Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
The HC allowed the appeal and set aside the addition of Rs.25,00,000 made by the AO and upheld by the CIT(A) and the Tribunal, concluding the estimation lacked any material or rational basis. The court found no justification to infer undisclosed sales or suppress books where purchases and sales were duly recorded and the purchase price rose due to foreign exchange movements. The AO's conclusion of a dip in gross profit, based on the fact that approximately 95% of sales were to a related concern, was unsupported by comparative data from like business periods; the Tribunal's contrary finding was characterized as perverse. Relief granted to the assessee; addition deleted.
The HC allowed the appeal and set aside the addition of Rs.25,00,000 made by the AO and upheld by the CIT(A) and the Tribunal, concluding the estimation lacked any material or rational basis. The court found no justification to infer undisclosed sales or suppress books where purchases and sales were duly recorded and the purchase price rose due to foreign exchange movements. The AO's conclusion of a dip in gross profit, based on the fact that approximately 95% of sales were to a related concern, was unsupported by comparative data from like business periods; the Tribunal's contrary finding was characterized as perverse. Relief granted to the assessee; addition deleted.
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