Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
Addition under section 69A was sustained where the assessee's statement under section 132(4) was linked to seized material and not rebutted by credible evidence. The Tribunal found this was not a bare confession: the seized document recovered during search provided the incriminating basis, the assessee gave a detailed explanation of the cash loan, source, interest arrangement and proposed recovery, and the statement was not retracted for a long period. The later claim that the figure represented cheque recoveries was held inconsistent with the ledger account, which showed no outstanding receivable on the date of search. The addition was therefore upheld and the appeal dismissed.
Addition under section 69A was sustained where the assessee's statement under section 132(4) was linked to seized material and not rebutted by credible evidence. The Tribunal found this was not a bare confession: the seized document recovered during search provided the incriminating basis, the assessee gave a detailed explanation of the cash loan, source, interest arrangement and proposed recovery, and the statement was not retracted for a long period. The later claim that the figure represented cheque recoveries was held inconsistent with the ledger account, which showed no outstanding receivable on the date of search. The addition was therefore upheld and the appeal dismissed.
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