Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Whether income could be extrapolated from a list of purported employees found during a survey: the Tribunal held that additions must be confined to incriminating material seized during survey and cannot be extrapolated without independent corroboration; reliance on precedent rejecting extrapolation further supports this reasoning, therefore extrapolation across months was unsustainable and disallowed. Consequence: the addition is restricted to Rs. 2,54,115 as per the seized document, taxed under section 69C read with section 115BBE; appeal partly allowed. - ITAT
Whether income could be extrapolated from a list of purported employees found during a survey: the Tribunal held that additions must be confined to incriminating material seized during survey and cannot be extrapolated without independent corroboration; reliance on precedent rejecting extrapolation further supports this reasoning, therefore extrapolation across months was unsustainable and disallowed. Consequence: the addition is restricted to Rs. 2,54,115 as per the seized document, taxed under section 69C read with section 115BBE; appeal partly allowed. - ITAT
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