Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
On additions for suppressed turnover detected from seized loose sheets, the tribunal held that ad hoc estimation of net profit at 18% by the AO, reduced to 15% by the first appellate authority without proper factual basis, was unsustainable; the AO was directed to accept the suppressed turnover and the profit computation prepared by the assessee on the basis of the seized material, allowing the assessee's appeal and rejecting the revenue's grounds on this issue. On disclosed turnover, rejection of audited books under s.145(3) and estimation of 14% net profit were held unjustified absent specific defects or a show-cause basis; deletion of the addition was upheld, and the revenue's appeal was dismissed. - ITAT
On additions for suppressed turnover detected from seized loose sheets, the tribunal held that ad hoc estimation of net profit at 18% by the AO, reduced to 15% by the first appellate authority without proper factual basis, was unsustainable; the AO was directed to accept the suppressed turnover and the profit computation prepared by the assessee on the basis of the seized material, allowing the assessee's appeal and rejecting the revenue's grounds on this issue. On disclosed turnover, rejection of audited books under s.145(3) and estimation of 14% net profit were held unjustified absent specific defects or a show-cause basis; deletion of the addition was upheld, and the revenue's appeal was dismissed. - ITAT
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