Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
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Whether unexplained cash deposits could be bifurcated and subjected to best judgment addition under section 144: Tribunal found bifurcation unjustified because the assessee's sole source of deposits was business receipts from trading in cement and iron-highly competitive commodities-so there was no rational basis for segregating half the deposits as unexplained; consequence: separate addition of unexplained cash deposits set aside. Appropriate profit rate to estimate business income: applying commercial realities and comparable profit standards, Tribunal directed AO to adopt a 6% profit rate on entire receipts and recompute income; appeal partly allowed. - ITAT
Whether unexplained cash deposits could be bifurcated and subjected to best judgment addition under section 144: Tribunal found bifurcation unjustified because the assessee's sole source of deposits was business receipts from trading in cement and iron-highly competitive commodities-so there was no rational basis for segregating half the deposits as unexplained; consequence: separate addition of unexplained cash deposits set aside. Appropriate profit rate to estimate business income: applying commercial realities and comparable profit standards, Tribunal directed AO to adopt a 6% profit rate on entire receipts and recompute income; appeal partly allowed. - ITAT
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