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ITAT dismissed Revenue's appeals and partly allowed assessee's appeal. It upheld CIT(A)'s deletion of additions treated as business receipts from a joint development agreement, holding that, in absence of valid seized material in search assessments under s.143(3) r.w.s. 153D, sworn statements alone could not sustain additions and that receipts were taxable in the year of execution of sale deeds, not on receipt of advances. ITAT further held that disallowance for non-capitalization of interest was unjustified where borrowings and interest were genuine, business-related, and undisputed, and where the AO's approach only caused a timing distortion without corresponding adjustment in later years. The interest disallowance of Rs.3.08 crores was deleted.
ITAT dismissed Revenue's appeals and partly allowed assessee's appeal. It upheld CIT(A)'s deletion of additions treated as business receipts from a joint development agreement, holding that, in absence of valid seized material in search assessments under s.143(3) r.w.s. 153D, sworn statements alone could not sustain additions and that receipts were taxable in the year of execution of sale deeds, not on receipt of advances. ITAT further held that disallowance for non-capitalization of interest was unjustified where borrowings and interest were genuine, business-related, and undisputed, and where the AO's approach only caused a timing distortion without corresponding adjustment in later years. The interest disallowance of Rs.3.08 crores was deleted.
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