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    <title>2023 (3) TMI 612 - ITAT AHMEDABAD</title>
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    <description>The Tribunal held that the surrender made during the survey without incriminating material and on an adhoc basis did not necessarily represent profits to be included in the book profits. The absence of substantiating evidence meant the surrender could not be deemed undisclosed income requiring inclusion in the profit and loss account. A detailed analysis and debate were deemed necessary for such inclusions. Consequently, the adjustment made by the AO under section 154 was not a patent error and was directed to be deleted, resulting in the appeal of the assessee being allowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=435226</link>
      <description>The Tribunal held that the surrender made during the survey without incriminating material and on an adhoc basis did not necessarily represent profits to be included in the book profits. The absence of substantiating evidence meant the surrender could not be deemed undisclosed income requiring inclusion in the profit and loss account. A detailed analysis and debate were deemed necessary for such inclusions. Consequently, the adjustment made by the AO under section 154 was not a patent error and was directed to be deleted, resulting in the appeal of the assessee being allowed.</description>
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