Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
ITAT held that estimated gross on-money receipts could not be taxed in full where the record also showed unaccounted funds being routed into the books as unsecured loans through the admitted modus operandi. Because the assessee failed to prove the genuineness and creditworthiness of the lenders, the unsecured loans were treated as unexplained and the CIT(A)'s restricted additions were sustained for the relevant assessment years. The Tribunal also rejected further telescoping based on income earlier declared, and upheld the CIT(A)'s approach as the correct basis of taxation. The Revenue's appeal and the assessee's appeals were dismissed.
ITAT held that estimated gross on-money receipts could not be taxed in full where the record also showed unaccounted funds being routed into the books as unsecured loans through the admitted modus operandi. Because the assessee failed to prove the genuineness and creditworthiness of the lenders, the unsecured loans were treated as unexplained and the CIT(A)'s restricted additions were sustained for the relevant assessment years. The Tribunal also rejected further telescoping based on income earlier declared, and upheld the CIT(A)'s approach as the correct basis of taxation. The Revenue's appeal and the assessee's appeals were dismissed.
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