Tax appeal allowed: AO exceeded s.144C DRP mandate by introducing new findings and recharacterising non-resident receipts as permanent establishment i...
ITAT dismissed the assessee's challenge to the transfer of jurisdiction u/s 127, holding that participation in assessment without timely objection u/s 124(3) precluded such plea. ITAT upheld the estimation of gross profit at 35% for AYs 2005-06 and 2006-07 as reasonable, based on the assessee's own past results and telescoping already granted. For AY 2007-08, ITAT rejected further GP addition, holding no basis for enhancement post-search. Additions towards alleged unaccounted initial investment in stock, unexplained investment in immovable property, unaccounted stock (gold and major part of silver), unexplained cash/advances u/ss 69A/69C, loose papers (including "Roop Sangam"), and gold transactions with a third party were all deleted for lack of corroborative evidence and to avoid double taxation. Overall, Revenue's multiple additions were largely disallowed, save for sustained GP estimation for specified years.
ITAT dismissed the assessee's challenge to the transfer of jurisdiction u/s 127, holding that participation in assessment without timely objection u/s 124(3) precluded such plea. ITAT upheld the estimation of gross profit at 35% for AYs 2005-06 and 2006-07 as reasonable, based on the assessee's own past results and telescoping already granted. For AY 2007-08, ITAT rejected further GP addition, holding no basis for enhancement post-search. Additions towards alleged unaccounted initial investment in stock, unexplained investment in immovable property, unaccounted stock (gold and major part of silver), unexplained cash/advances u/ss 69A/69C, loose papers (including "Roop Sangam"), and gold transactions with a third party were all deleted for lack of corroborative evidence and to avoid double taxation. Overall, Revenue's multiple additions were largely disallowed, save for sustained GP estimation for specified years.
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