Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
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Adjustment made u/s 115JB in Rectification order u/s 154 - Debatable issue - addition of surrendered income by the assessee was included in the book profit of the assessee as per Section 115JB - The Revenue argued that the disclosed income should be considered as part of the book profit for tax calculation purposes. However, the respondent contended that the inclusion of this income required extensive debate and was not supported by incriminating material found during the survey. The Tribunal agreed with the respondent, concluding that the Assessing Officer's action under Section 154 was unwarranted due to the debatable nature of the issue. Consequently, the Tribunal dismissed the appeal of the Revenue.
Adjustment made u/s 115JB in Rectification order u/s 154 - Debatable issue - addition of surrendered income by the assessee was included in the book profit of the assessee as per Section 115JB - The Revenue argued that the disclosed income should be considered as part of the book profit for tax calculation purposes. However, the respondent contended that the inclusion of this income required extensive debate and was not supported by incriminating material found during the survey. The Tribunal agreed with the respondent, concluding that the Assessing Officer's action under Section 154 was unwarranted due to the debatable nature of the issue. Consequently, the Tribunal dismissed the appeal of the Revenue.
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