https://www.taxtmi.com/caselaws?id=438284 Rejection of books and trading additions for the Baddi unit were found unsustainable because no specific defects, such as suppressed sales, unrecorded purchases, or defective vouchers, were established, and the comparison with the Guwahati unit was unreliable given different operating conditions. Multiple ad hoc disallowances, including expenses, R&D, wastage, excise-duty related addition, interest, unsecured loans, sundry creditors, business asset expenditure, and closing stock, were also deleted because they rested on suspicion rather than adverse material and the supporting records showed business nexus. Deduction for the Guwahati unit under section 80IB / 80IC was allowed because it was an independently established industrial undertaking with separate books and operations, not a reconstruction or split-up of the Baddi unit. en-us Thu, 06 Apr 2023 00:00:00 +0530 Fri, 26 May 2023 16:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438284 Rejection of books and trading additions for the Baddi unit were found unsustainable because no specific defects, such as suppressed sales, unrecorded purchases, or defective vouchers, were established, and the comparison with the Guwahati unit was unreliable given different operating conditions. Multiple ad hoc disallowances, including expenses, R&D, wastage, excise-duty related addition, interest, unsecured loans, sundry creditors, business asset expenditure, and closing stock, were also deleted because they rested on suspicion rather than adverse material and the supporting records showed business nexus. Deduction for the Guwahati unit under section 80IB / 80IC was allowed because it was an independently established industrial undertaking with separate books and operations, not a reconstruction or split-up of the Baddi unit. Case-Laws Income Tax Thu, 06 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438284