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    <title>Ruling partly allows department appeals on search statement admissibility; deletes unauthorised additions, curtails extrapolation, upholds s.80IA deduction, deletes ss.69A/69C additions</title>
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    <description>The ITAT allowed in part the Department&#039;s appeals regarding admissibility of a statement recorded during search, finding the assessee failed to prove duress in retraction; grounds 1-7 of the Department&#039;s appeal were allowed. However, the Tribunal upheld the CIT(A)&#039;s deletions of additions based on documents seized from a third party&#039;s premises, holding no corroborative link to the assessee&#039;s books. An extrapolated addition for under-invoicing was curtailed and quantified at Rs.2.419 per kg for 230,407.20 kg supplied to a specified purchaser; wholesale extrapolation was disapproved. Additions under ss.69A and 69C were deleted. The Tribunal disallowed an enhancement of GP to 24%, allowed deduction under s.80IA for captive steam generation, and held the s.153A assessment unsustainable as not founded on incriminating material.</description>
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    <pubDate>Sat, 15 Nov 2025 07:56:56 +0530</pubDate>
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      <title>Ruling partly allows department appeals on search statement admissibility; deletes unauthorised additions, curtails extrapolation, upholds s.80IA deduction, deletes ss.69A/69C additions</title>
      <link>https://www.taxtmi.com/highlights?id=94192</link>
      <description>The ITAT allowed in part the Department&#039;s appeals regarding admissibility of a statement recorded during search, finding the assessee failed to prove duress in retraction; grounds 1-7 of the Department&#039;s appeal were allowed. However, the Tribunal upheld the CIT(A)&#039;s deletions of additions based on documents seized from a third party&#039;s premises, holding no corroborative link to the assessee&#039;s books. An extrapolated addition for under-invoicing was curtailed and quantified at Rs.2.419 per kg for 230,407.20 kg supplied to a specified purchaser; wholesale extrapolation was disapproved. Additions under ss.69A and 69C were deleted. The Tribunal disallowed an enhancement of GP to 24%, allowed deduction under s.80IA for captive steam generation, and held the s.153A assessment unsustainable as not founded on incriminating material.</description>
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      <pubDate>Sat, 15 Nov 2025 07:56:56 +0530</pubDate>
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