Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Where the assessee failed to produce cogent evidence of employment, salary receipt, commission or brokerage, the Tribunal upheld denial of the claimed standard deduction and treated the returned income as unexplained money under section 69A for A.Ys. 2019-20 and 2020-21. By contrast, where the assessee had opted for presumptive taxation under section 44AD and produced confirmations, sample bills and related business details, the Tribunal accepted that rice trading business was carried on and held that the same receipts could not again be taxed as unexplained money under section 69A, as that would amount to double taxation. The section 69A addition was deleted for A.Y. 2022-23, and the rice trading finding was applied for A.Y. 2021-22.
Where the assessee failed to produce cogent evidence of employment, salary receipt, commission or brokerage, the Tribunal upheld denial of the claimed standard deduction and treated the returned income as unexplained money under section 69A for A.Ys. 2019-20 and 2020-21. By contrast, where the assessee had opted for presumptive taxation under section 44AD and produced confirmations, sample bills and related business details, the Tribunal accepted that rice trading business was carried on and held that the same receipts could not again be taxed as unexplained money under section 69A, as that would amount to double taxation. The section 69A addition was deleted for A.Y. 2022-23, and the rice trading finding was applied for A.Y. 2021-22.
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