Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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Reliance on hypothecation statement to determine taxable income was upheld where the hypothecation statement recorded quantities and values, was certified as reflecting books of account, and showed substantial unexplained discrepancies with bank records; the AO's notional addition was justified because inflated stock declarations to secure higher bank credit constituted commercially immoral conduct and admissible material. On appellate review, the HC found the Tribunal's affirmation rested on proper appreciation of the record and was neither perverse nor unsupported by evidence, therefore appellate interference was unwarranted and the addition sustained.
Reliance on hypothecation statement to determine taxable income was upheld where the hypothecation statement recorded quantities and values, was certified as reflecting books of account, and showed substantial unexplained discrepancies with bank records; the AO's notional addition was justified because inflated stock declarations to secure higher bank credit constituted commercially immoral conduct and admissible material. On appellate review, the HC found the Tribunal's affirmation rested on proper appreciation of the record and was neither perverse nor unsupported by evidence, therefore appellate interference was unwarranted and the addition sustained.
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