https://www.taxtmi.com/caselaws?id=433608 Seized documents in a search carry a rebuttable presumption of truth under sections 132(4A) and 292C, and additions based on discrepancies with audited accounts may be remanded where the assessee seeks factual verification and explains the differences with supporting material; the disputed liability and expense additions were therefore sent back for fresh adjudication. Cash payments reflected in a seized cash book despite no available cash balance were treated as unexplained expenditure because the assessee failed to rebut the record with credible evidence; that addition was sustained. Marketing payments to distributors were treated as contractual payments attracting section 194C, so the section 40(a)(ia) disallowance was upheld in principle, subject to limited verification of payee tax compliance. An ad hoc 5% business expense disallowance was also remitted for fresh examination. en-us Wed, 01 Feb 2023 00:00:00 +0530 Fri, 03 Feb 2023 15:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433608 Seized documents in a search carry a rebuttable presumption of truth under sections 132(4A) and 292C, and additions based on discrepancies with audited accounts may be remanded where the assessee seeks factual verification and explains the differences with supporting material; the disputed liability and expense additions were therefore sent back for fresh adjudication. Cash payments reflected in a seized cash book despite no available cash balance were treated as unexplained expenditure because the assessee failed to rebut the record with credible evidence; that addition was sustained. Marketing payments to distributors were treated as contractual payments attracting section 194C, so the section 40(a)(ia) disallowance was upheld in principle, subject to limited verification of payee tax compliance. An ad hoc 5% business expense disallowance was also remitted for fresh examination. Case-Laws Income Tax Wed, 01 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433608