Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Unaccounted production addition was deleted because the comparison made by the AO was between unlike units, treating tablets/capsules in production charts as if they were strips in sales records. The Court accepted the concurrent findings of the CIT(A) and Tribunal that this erroneous comparison made the computation unsustainable. It also noted that there was no corroborative material showing excess raw material purchases, unaccounted manufacturing expenditure, or receipt of unaccounted sale proceeds, even after search. The Revenue's challenge was therefore confined to factual issues, and the appeal was dismissed for want of any substantial question of law.
Unaccounted production addition was deleted because the comparison made by the AO was between unlike units, treating tablets/capsules in production charts as if they were strips in sales records. The Court accepted the concurrent findings of the CIT(A) and Tribunal that this erroneous comparison made the computation unsustainable. It also noted that there was no corroborative material showing excess raw material purchases, unaccounted manufacturing expenditure, or receipt of unaccounted sale proceeds, even after search. The Revenue's challenge was therefore confined to factual issues, and the appeal was dismissed for want of any substantial question of law.
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