Cash routed to non-existent firm deemed proceeds of crime; laundered funds and properties attachable, provisional attachments confirmed; two accounts ...
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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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