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    <title>2020 (1) TMI 1115 - GUJARAT HIGH COURT</title>
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    <description>An addition for alleged under-invoicing of export sales could not be sustained merely on the basis of the Justice M.B. Shah Commission report. The Tribunal found that the Assessing Officer had not rejected the books of account, had not shown that true income could not be deduced from them, and had produced no independent evidence of under-invoicing or unaccounted sale proceeds. The Commission report was treated as tentative rather than conclusive, especially where contemporaneous commercial and customs documents supported the declared exports. The deletion of the addition was upheld, and no substantial question of law arose.</description>
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