Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Tribunal held that estimating undisclosed income by applying a percentage to sales turnover was unsustainable where books showed purchases and sales, payments passed through banking channels, no cash introductions were proved, and AO did not justify the rate; consequently additions based on turnover estimation were deleted. The tribunal upheld allowability of depreciation and indirect/finance expenses because expenditures were recorded, payments evidenced, and no material showed expenses were fictitious. Additions treating intra group unsecured loans as unexplained cash credits were deleted where creditor identity and creditworthiness, ledger entries, repayments, prior advances and bank records supported the transactions.
Tribunal held that estimating undisclosed income by applying a percentage to sales turnover was unsustainable where books showed purchases and sales, payments passed through banking channels, no cash introductions were proved, and AO did not justify the rate; consequently additions based on turnover estimation were deleted. The tribunal upheld allowability of depreciation and indirect/finance expenses because expenditures were recorded, payments evidenced, and no material showed expenses were fictitious. Additions treating intra group unsecured loans as unexplained cash credits were deleted where creditor identity and creditworthiness, ledger entries, repayments, prior advances and bank records supported the transactions.
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