Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
Tribunal addressed estimated additions made by the AO over recorded purchase and sales without first rejecting the books of account under applicable provisions; it held that where the AO accepts the genuineness of books he cannot independently compute estimated unrecorded sales or commission income without invoking rejection/estimation provisions, and such additions are arbitrary and unlawful. The Tribunal directed deletion of the estimated addition and allowed the appeal, applying precedent that books must be rejected before making estimation-based additions.
Tribunal addressed estimated additions made by the AO over recorded purchase and sales without first rejecting the books of account under applicable provisions; it held that where the AO accepts the genuineness of books he cannot independently compute estimated unrecorded sales or commission income without invoking rejection/estimation provisions, and such additions are arbitrary and unlawful. The Tribunal directed deletion of the estimated addition and allowed the appeal, applying precedent that books must be rejected before making estimation-based additions.
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