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    <title>2025 (9) TMI 209 - ITAT AHMEDABAD</title>
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    <description>ITAT AHMEDABAD - AT held that incriminating material found during searches on the assessee and its sub-contractors justified disallowance of bogus sub-contract expenses, but limited the quantum to 12.5% of such purchases. Section 153C was held inapplicable as the assessee was itself searched and assessments fall under s.153A. Denial of cross-examination of third parties was not fatal where independent adverse evidence existed. Invocations of ss.69A, 69C and 115BBE were deleted and deduction under s.80IA(4) restored. Additional deduction claimed in the revised return was treated as a fresh claim and disallowed. Assessment was time-barred under s.153B; ESOP disallowance deleted; s.35D claim allowed; ESI/PF issue decided against the assessee.</description>
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    <pubDate>Fri, 10 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (9) TMI 209 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=777720</link>
      <description>ITAT AHMEDABAD - AT held that incriminating material found during searches on the assessee and its sub-contractors justified disallowance of bogus sub-contract expenses, but limited the quantum to 12.5% of such purchases. Section 153C was held inapplicable as the assessee was itself searched and assessments fall under s.153A. Denial of cross-examination of third parties was not fatal where independent adverse evidence existed. Invocations of ss.69A, 69C and 115BBE were deleted and deduction under s.80IA(4) restored. Additional deduction claimed in the revised return was treated as a fresh claim and disallowed. Assessment was time-barred under s.153B; ESOP disallowance deleted; s.35D claim allowed; ESI/PF issue decided against the assessee.</description>
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      <pubDate>Fri, 10 Jan 2025 00:00:00 +0530</pubDate>
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