Topic
ITAT Pune rules that unaccounted cash receipts ('on-money') must be assessed under the unified peak credit method, striking down separate additions under Section 69A. The decision mandates a single peak computation for undisclosed income, preventing double taxation and ensuring consistency in tax assessments for real estate developers.
ITAT Ahmedabad rules that only the profit component of on-money receipts is taxable at 15%, while unaccounted expenditures can be offset against such income if sufficient funds exist. The ruling clarifies the scope of taxable income under Sections 69A and 69C, offering relief to taxpayers facing additions for undisclosed transactions.
ITAT Ranchi slashed the presumptive profit rate from 8% to 3% for an unaccounted electronic goods business, ruling that tax authorities cannot impose arbitrary additions without rejecting books or proving higher margins. The decision reinforces that presumptive taxation under Section 44AD must align with actual business performance, protecting small traders from speculative assessments.
ITAT Delhi rules that net profit calculations in search assessments under Section 143(3) must rely on actual figures from seized documents, rejecting uniform gross profit estimates. The decision reinforces that expense deductions require concrete evidence, not presumptive additions, impacting undisclosed income assessments for businesses.