Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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Cash advances treated as receipts: Held that cash receipts were advances and under the assessee's established project-completion accounting could not be taxed in the relevant AY but only on project completion; appeal allowed on this issue. Unexplained purchase payments: Addition deleted because corresponding additions in purchasers' hands were removed and statements relied upon were not furnished, vitiating the addition; upheld deletion. Interest disallowance: Deleted since own capital exceeded interest-free advances, permitting presumption advances made from own funds; disallowance overturned. Deemed rent under s.22: sustained. Reassessment valid. TDS non-deduction remitted to AO for verification. Section 68 additions on opening balances deleted. - ITAT
Cash advances treated as receipts: Held that cash receipts were advances and under the assessee's established project-completion accounting could not be taxed in the relevant AY but only on project completion; appeal allowed on this issue. Unexplained purchase payments: Addition deleted because corresponding additions in purchasers' hands were removed and statements relied upon were not furnished, vitiating the addition; upheld deletion. Interest disallowance: Deleted since own capital exceeded interest-free advances, permitting presumption advances made from own funds; disallowance overturned. Deemed rent under s.22: sustained. Reassessment valid. TDS non-deduction remitted to AO for verification. Section 68 additions on opening balances deleted. - ITAT
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