Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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Where additional income declared during search was credited as loans, it was held that, since the taxpayer's only activity was land trading and the amount was already offered and accepted as business income, it could not be taxed as unexplained cash credit under s.68 read with s.115BBE; the addition was deleted. On alleged on-money enhancing capital gains, unsigned and undated seized notings and lack of corroboration, coupled with some plots not being sold as alleged, were held insufficient; the addition was deleted. Direction to verify telescoping/set-off of disclosed income against other additions was sustained. Deletion of s.69C addition was upheld for want of error in appreciation of explained expenditure. Addition under s.69 read with s.115BBE based on cancelled loose-paper notings, without corroboration, was set aside. - ITAT
Where additional income declared during search was credited as loans, it was held that, since the taxpayer's only activity was land trading and the amount was already offered and accepted as business income, it could not be taxed as unexplained cash credit under s.68 read with s.115BBE; the addition was deleted. On alleged on-money enhancing capital gains, unsigned and undated seized notings and lack of corroboration, coupled with some plots not being sold as alleged, were held insufficient; the addition was deleted. Direction to verify telescoping/set-off of disclosed income against other additions was sustained. Deletion of s.69C addition was upheld for want of error in appreciation of explained expenditure. Addition under s.69 read with s.115BBE based on cancelled loose-paper notings, without corroboration, was set aside. - ITAT
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