ITAT held that seized material and search statements did not...

ITAT held that seized material and search statements did not conclusively establish falsification of entries or bogus purchase invoices, though accounting deficiencies justified rejection of books under s.145. It upheld the CIT(A)'s best judgment assessment under s.144, sustaining estimation of business profits at 10% of turnover, following industry comparables and the Empee Distilleries precedent. ITAT further ruled that, once income is estimated, separate disallowances (including data centre expenses and addition on sale of scrap) and additions under s.68 are impermissible, all deductions being subsumed in the profit estimate. Disallowance of CSR expenditure was also deleted as no deduction had been claimed. The Revenue's appeal was accordingly dismissed.

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