https://www.taxtmi.com/caselaws?id=445304 The ITAT Surat upheld CIT(A)'s order limiting on-money income estimation to 25% for only 23 specific buyers whose details were found during search proceedings under Section 132. The tribunal rejected AO's extrapolation of on-money receipts across the entire saleable area of a real estate project, finding no incriminating material or corroborative evidence for remaining buyers. The court emphasized that both receipts and expenditures from seized documents must be considered together when estimating income. Revenue's appeal was dismissed as the CIT(A) was justified in restricting additions to persons specifically identified in seized materials rather than applying blanket assumptions. en-us Tue, 31 Oct 2023 00:00:00 +0530 Sun, 05 Nov 2023 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445304 The ITAT Surat upheld CIT(A)'s order limiting on-money income estimation to 25% for only 23 specific buyers whose details were found during search proceedings under Section 132. The tribunal rejected AO's extrapolation of on-money receipts across the entire saleable area of a real estate project, finding no incriminating material or corroborative evidence for remaining buyers. The court emphasized that both receipts and expenditures from seized documents must be considered together when estimating income. Revenue's appeal was dismissed as the CIT(A) was justified in restricting additions to persons specifically identified in seized materials rather than applying blanket assumptions. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445304