Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
ITAT determined that excess stock discovered on survey comprised trading/manufacturing goods and constituted income from business; therefore it should be assessed under the head 'income from business' rather than as deemed income attractable to special taxation provisions. The tribunal found admissions during survey and absence of evidence of non-business sources supported business classification, directed the AO to permit set off of current year and carried forward business losses and depreciation against the assessed business income, and directed that special rate taxation provisions not be applied.
ITAT determined that excess stock discovered on survey comprised trading/manufacturing goods and constituted income from business; therefore it should be assessed under the head 'income from business' rather than as deemed income attractable to special taxation provisions. The tribunal found admissions during survey and absence of evidence of non-business sources supported business classification, directed the AO to permit set off of current year and carried forward business losses and depreciation against the assessed business income, and directed that special rate taxation provisions not be applied.
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