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    <title>Tax Authorities Cannot Disallow Legitimate Journal Entries Without Evidence of Bogus Expenses Under Section 145(3)</title>
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    <description>ITAT overturned the AO&#039;s disallowance of Rs.36,25,56,616 across five assessment years for alleged bogus bulk journal entries, finding they were legitimate transfers between ledger accounts. The Tribunal upheld CIT(A)&#039;s findings that individual site operating expenses were properly documented with TDS deductions, year-end provisions were valid, and cash payments for coolie and wages couldn&#039;t be entirely disallowed as bogus. ITAT rejected Revenue&#039;s alternative arguments under s.40A(3) and s.40(a)(ia), noting these provisions were inapplicable to the expenses in question. However, the Tribunal agreed with CIT(A) on rejecting the assessee&#039;s books under s.145(3), but modified the profit estimation from 12.5% to 10% of contractual receipts, considering contemporary economic conditions rather than outdated precedents from the 1980s-90s.</description>
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    <pubDate>Thu, 03 Apr 2025 07:50:41 +0530</pubDate>
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      <title>Tax Authorities Cannot Disallow Legitimate Journal Entries Without Evidence of Bogus Expenses Under Section 145(3)</title>
      <link>https://www.taxtmi.com/highlights?id=87090</link>
      <description>ITAT overturned the AO&#039;s disallowance of Rs.36,25,56,616 across five assessment years for alleged bogus bulk journal entries, finding they were legitimate transfers between ledger accounts. The Tribunal upheld CIT(A)&#039;s findings that individual site operating expenses were properly documented with TDS deductions, year-end provisions were valid, and cash payments for coolie and wages couldn&#039;t be entirely disallowed as bogus. ITAT rejected Revenue&#039;s alternative arguments under s.40A(3) and s.40(a)(ia), noting these provisions were inapplicable to the expenses in question. However, the Tribunal agreed with CIT(A) on rejecting the assessee&#039;s books under s.145(3), but modified the profit estimation from 12.5% to 10% of contractual receipts, considering contemporary economic conditions rather than outdated precedents from the 1980s-90s.</description>
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      <pubDate>Thu, 03 Apr 2025 07:50:41 +0530</pubDate>
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