Third-party seized records require corroboration, while Rule 8D cannot increase minimum alternate tax book profit.
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....Third-party seized diaries and excel sheets cannot support additions for alleged cash rebate repayment or unaccounted molasses sales unless they clearly establish the transactions and are supported by independent corroborative evidence. Unsigned, ambiguous entries, a retracted statement, and denial of cross-examination undermine their evidentiary value and breach natural justice; the related additions were deleted. Disallowance computed under section 14A read with Rule 8D cannot be imported into book-profit computation under section 115JB, requiring deletion of that adjustment. Components integral to a cogeneration plant, without standalone function, qualify for the higher depreciation rate applicable to the plant; the depreciation disallowance was deleted.....
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