Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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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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