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    <title>2024 (1) TMI 795 - ITAT CHANDIGARH</title>
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    <description>ITAT Chandigarh ruled on the nature of income surrendered during survey proceedings. The assessee surrendered an amount after being unable to explain the source of capital introduced in financial year 2018-19. The tribunal held that provisions of Section 68 applied to the unexplained capital credit entry due to lack of explanation from the assessee. However, regarding excess stock found during survey, the tribunal distinguished that since there was no physical distinction between accounted and unaccounted stock, the difference represented business receipts rather than undisclosed assets under Section 69. The tribunal directed assessment of surrendered income as business income at normal tax rates, not under deeming provisions requiring higher taxation under Section 115BBE.</description>
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      <title>2024 (1) TMI 795 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=448396</link>
      <description>ITAT Chandigarh ruled on the nature of income surrendered during survey proceedings. The assessee surrendered an amount after being unable to explain the source of capital introduced in financial year 2018-19. The tribunal held that provisions of Section 68 applied to the unexplained capital credit entry due to lack of explanation from the assessee. However, regarding excess stock found during survey, the tribunal distinguished that since there was no physical distinction between accounted and unaccounted stock, the difference represented business receipts rather than undisclosed assets under Section 69. The tribunal directed assessment of surrendered income as business income at normal tax rates, not under deeming provisions requiring higher taxation under Section 115BBE.</description>
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