Daily Archives: December 17, 2025

ADDITION BASED ON THIRD-PARTY EXCEL SHEETS & RETRACTED STATEMENTS DELETED

By | December 17, 2025

ADDITION BASED ON THIRD-PARTY EXCEL SHEETS & RETRACTED STATEMENTS DELETED ISSUE Whether additions for unexplained money and capital gains can be sustained solely on the basis of Excel-based MIS sheets found with a third party and statements that were subsequently retracted, without any independent corroboration or examination of the alleged transacting parties. FACTS Search Operation:… Read More »

ADDITIONS ON BOGUS SUB-CONTRACTOR PAYMENTS DELETED: DOCUMENTARY EVIDENCE PREVAILS OVER SEARCH STATEMENTS

By | December 17, 2025

ADDITIONS ON BOGUS SUB-CONTRACTOR PAYMENTS DELETED: DOCUMENTARY EVIDENCE PREVAILS OVER SEARCH STATEMENTS ISSUE Whether additions for unexplained expenditure (bogus sub-contractor payments) under Section 69C can be sustained solely based on statements recorded under Section 132(4) during a search, despite the assessee providing substantial documentary evidence (work orders, bills, affidavits) which remained uncontroverted by the Assessing… Read More »

REVISION UNDER SECTION 263 QUASHED: COMPUTER PERIPHERALS ARE REVENUE EXPENDITURE IN COST+ MODEL

By | December 17, 2025

REVISION UNDER SECTION 263 QUASHED: COMPUTER PERIPHERALS ARE REVENUE EXPENDITURE IN COST+ MODEL   ISSUE Whether the Principal Commissioner (PCIT) can validly invoke Section 263 to treat the cost of computer peripherals (such as mouse and headsets) as Capital Expenditure instead of Revenue Expenditure, specifically when the assessee operates on a “Cost Plus” model where… Read More »