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    <title>2013 (11) TMI 938 - ITAT MUMBAI</title>
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    <description>Loose sheets and a note book found during survey were treated as reliable material rather than dumb documents because the entries were date-wise, monetary and consistent with undisclosed business receipts. A survey statement, though not conclusive, can support an addition when backed by seized material; the assessee&#039;s shifting explanations and unsupported retraction did not displace the inference of suppression. For quantification, the full entries were not to be taxed as income without considering expenditure, so an estimated 10% profit element was sustained as reasonable. The separate disallowance of expenditure lacked definite findings and was remitted for a fresh speaking order after hearing both sides.</description>
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      <link>https://www.taxtmi.com/caselaws?id=239761</link>
      <description>Loose sheets and a note book found during survey were treated as reliable material rather than dumb documents because the entries were date-wise, monetary and consistent with undisclosed business receipts. A survey statement, though not conclusive, can support an addition when backed by seized material; the assessee&#039;s shifting explanations and unsupported retraction did not displace the inference of suppression. For quantification, the full entries were not to be taxed as income without considering expenditure, so an estimated 10% profit element was sustained as reasonable. The separate disallowance of expenditure lacked definite findings and was remitted for a fresh speaking order after hearing both sides.</description>
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