Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
The Income Tax Appellate Tribunal held that when the assessing officer considered undisclosed income based on seized material, they ought to have also considered undisclosed losses from the same material and allowed set-off. Failing to do so constituted a mistake apparent from record u/s 254(2). The Tribunal directed the assessing officer to allow set-off of undisclosed losses of the immediately preceding year against the undisclosed income for the impugned year, following principles of equity, justice and interpreting seized material as a whole.
The Income Tax Appellate Tribunal held that when the assessing officer considered undisclosed income based on seized material, they ought to have also considered undisclosed losses from the same material and allowed set-off. Failing to do so constituted a mistake apparent from record u/s 254(2). The Tribunal directed the assessing officer to allow set-off of undisclosed losses of the immediately preceding year against the undisclosed income for the impugned year, following principles of equity, justice and interpreting seized material as a whole.
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