HC declined to address allocation of undisclosed Shilpgram...

HC declined to address allocation of undisclosed Shilpgram Scheme income between parties as factual matter, upholding Tribunal's 70-30 split. On interest charges under s.158BFA(1), court affirmed Tribunal's ruling that assessee could not be charged interest for delayed return filing during period when seized documents were unavailable. Court determined interest charges inappropriate until photocopies of seized materials were provided to assessee, as compilation of return was impossible without access to these documents. Question regarding income allocation dismissed as factual; interest charge question resolved in assessee's favor.

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