Electronic Evidence and Tax Valuation: ITAT Clarifies Admissibility, Profit Calculations, and Evidence Standards in Complex Assessment

ITAT upheld the CIT(A)'s order with key findings: (1) Electronic evidence seized during search was admissible under Section 65B of Indian Evidence Act, (2) Cash receipts from property sales would be taxed only on profit element estimated at 12.5%, (3) For eight plots, matter was remanded to AO for reference to DVO under Section 43CA, (4) Unaccounted scrap sales addition of 20% was confirmed, (5) Bogus steel purchase addition limited to 17% profit element, (6) Salary disallowance to an employee was deleted due to lack of corroborative evidence, and (7) Disallowance under Sections 40A(3) and 37 was rejected as no substantive evidence supported the addition. Overall, most additions were either deleted or substantially reduced. .....

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