Held that based on the transactions recorded in the seized material, diary notings, which are transfer within group which are taxed in respective entities. Once again addition based on same material is deleted. The Tribunal held that the CIT(A) is justified in adopting a profit rate of 30 per cent on total receipts, based on principle of taxing real income.(AY. 2016-17 to 2019-20)
Kailash Ramavatar Goenka. v. ACIT (2025) 211 ITD 317 (Ahd) (Trib.)
S. 69C: Unexplained expenditure-Un accounted cash-Seized material, diary notings-Transfer within group-Taxed in respective entities-Addition is deleted-Unexplained receipts and payments-Estimation of gross receipts-CIT(A) is justified in adopting a profit rate of 30 per cent on total receipts, based on principle of taxing real income.
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