SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
The Income Tax Appellate Tribunal held that the Assessing Officer cannot arbitrarily reduce agricultural income and add it as income from other sources based on mere estimation and assumption without any specific material evidence. Suspicion alone cannot substitute proof. The Assessing Officer acted on surmises and conjectures by adopting 50% of net agricultural income as income from other sources without any basis or further verification. The Tribunal observed that in the same assessee's case for other assessment years, the Assessing Officer accepted the source as agricultural income, passing assessment orders u/s 143(3) without drawing any adverse inference. Consequently, the Tribunal set aside the order of the Commissioner of Income Tax (Appeals) and allowed the assessee's appeal.
The Income Tax Appellate Tribunal held that the Assessing Officer cannot arbitrarily reduce agricultural income and add it as income from other sources based on mere estimation and assumption without any specific material evidence. Suspicion alone cannot substitute proof. The Assessing Officer acted on surmises and conjectures by adopting 50% of net agricultural income as income from other sources without any basis or further verification. The Tribunal observed that in the same assessee's case for other assessment years, the Assessing Officer accepted the source as agricultural income, passing assessment orders u/s 143(3) without drawing any adverse inference. Consequently, the Tribunal set aside the order of the Commissioner of Income Tax (Appeals) and allowed the assessee's appeal.
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TaxTMI 
TaxTMI 
of 4879 
