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    <title>2018 (1) TMI 1682 - ITAT RAJKOT</title>
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    <description>Rough survey notebooks and diary entries that are not regular books of account cannot, by themselves, be taxed as unexplained cash credits, advances, investments or fictitious liabilities; only the profit element embedded in unrecorded business transactions may be brought to tax. Trade discounts passed on to travel agents on air-ticket sales were treated as principal-to-principal transactions, so no tax deduction at source was required and disallowance under section 40(a)(ia) failed. Where interest-free funds exceeded interest-free advances, no nexus with borrowed funds was shown and interest disallowance was deleted. Estimated disallowances for business expenses and low household withdrawals were sustained, while penalty for concealment was held unsustainable because the additions were based on estimation rather than proved concealment.</description>
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    <pubDate>Thu, 04 Jan 2018 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=302338</link>
      <description>Rough survey notebooks and diary entries that are not regular books of account cannot, by themselves, be taxed as unexplained cash credits, advances, investments or fictitious liabilities; only the profit element embedded in unrecorded business transactions may be brought to tax. Trade discounts passed on to travel agents on air-ticket sales were treated as principal-to-principal transactions, so no tax deduction at source was required and disallowance under section 40(a)(ia) failed. Where interest-free funds exceeded interest-free advances, no nexus with borrowed funds was shown and interest disallowance was deleted. Estimated disallowances for business expenses and low household withdrawals were sustained, while penalty for concealment was held unsustainable because the additions were based on estimation rather than proved concealment.</description>
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