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The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
Where updated cash books explained the cash found and no defects were pointed out, additions under section 69A were held unsustainable. Substantiation with regular books prevailed over search-time snapshots.
The assessee relied on deemed payment after transferring employee dues to another entity. The Tribunal ruled that section 43B recognises only real payment and set aside the relief granted by the appellate authority.
The issue was whether revision under section 263 could be invoked when the Assessing Officer had accepted a legally possible view. The Tribunal held that where two views exist and the AO adopts one, the order is neither erroneous nor prejudicial.
The Tribunal held that search-based reassessments issued beyond six assessment years are barred by limitation. Revenue appeals were dismissed as the statutory time limits could not be extended.
The ITAT ruled that taxing section 28 interest as income from other sources through rectification was invalid. Where the issue is debatable and supported by binding precedent, section 154 cannot be invoked.
The tribunal held that revision under Section 263 is invalid where the Assessing Officer has examined the issue and adopted a plausible legal view. The PCIT cannot substitute his opinion merely because another interpretation is possible.
It was ruled that under-reported revenue cannot be inferred solely from service tax data when no defects are found in regularly maintained books. Income must be assessed on real income principles supported by enquiry and evidence.
The Tribunal held that IGST demand based on alleged breach of pre-import condition was unsustainable where export obligations were fulfilled and EODCs were issued. Acceptance of EODCs and bond cancellation closed the exemption compliance.
The Tribunal held that interest under Section 28 is part of compensation and not taxable as other income. A reopening based on such misinterpretation was quashed for lack of valid belief.
