ITAT Mumbai: On-Money Taxed at 8%, Subcontract Disallowance Deleted – Real Estate Additions Rationalised

DCIT Vs Horizon Projects Private Limited (ITAT Mumbai) In a detailed and landmark ruling, the ITAT Mumbai dealt with multiple additions arising from a search in a real estate group, including on-money receipts, cash expenditure (Section 69C), and subcontracting expenses. On the issue of on-money receipts, the Tribunal held that entire gross receipts cannot be taxed. Following settled jurisprudence, it ruled that only the profit element embedded in such receipts is taxable, considering that such receipts are business in nature and involve corresponding outflows. While the CIT(A) had estimated p...