https://www.taxtmi.com/caselaws?id=754860 The ITAT HC upheld additions made by AO based on documents seized from third party premises, rejecting the assessee's argument about lack of corroborative evidence. The assessee had admitted Rs. 7,13,73,002/- and additional Rs. 1,48,99,595/- as inadmissible expenditure during assessment proceedings. The tribunal denied set-off claims against income already declared in revised returns, stating assessees cannot indirectly obtain what is directly impermissible. Deduction under section 80IA was allowed following consistency principle and AO's confirmation of fulfilled conditions. ESOP expenditure under section 37 was permitted based on Karnataka HC precedent in Biocon Ltd. The tribunal partially allowed relief, reducing one addition from Rs. 1,08,18,780/- to Rs. 36,68,780/- while deleting Rs. 71,50,000/- portion lacking evidence of illegal commission payments. en-us Wed, 31 Jan 2024 00:00:00 +0530 Mon, 01 Jul 2024 12:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754860 The ITAT HC upheld additions made by AO based on documents seized from third party premises, rejecting the assessee's argument about lack of corroborative evidence. The assessee had admitted Rs. 7,13,73,002/- and additional Rs. 1,48,99,595/- as inadmissible expenditure during assessment proceedings. The tribunal denied set-off claims against income already declared in revised returns, stating assessees cannot indirectly obtain what is directly impermissible. Deduction under section 80IA was allowed following consistency principle and AO's confirmation of fulfilled conditions. ESOP expenditure under section 37 was permitted based on Karnataka HC precedent in Biocon Ltd. The tribunal partially allowed relief, reducing one addition from Rs. 1,08,18,780/- to Rs. 36,68,780/- while deleting Rs. 71,50,000/- portion lacking evidence of illegal commission payments. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754860