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    <title>1976 (7) TMI 7 - BOMBAY High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=38363</link>
    <description>The proviso to section 13 of the Indian Income-tax Act, 1922 could not support an addition unless the Revenue proved that the assessee-company itself accrued or received the alleged income. The Tribunal found no evidence that the company received amounts beyond the contractual prices, and no nexus was shown between any alleged manipulation by managing agents and the company&#039;s actual receipts. The question whether excess income had been received was treated as one of fact, and the factual finding was that no such income accrued or was received by the assessee-company. The disputed addition was therefore not justified and the Tribunal&#039;s deletion was upheld.</description>
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    <pubDate>Thu, 01 Jul 1976 00:00:00 +0530</pubDate>
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      <title>1976 (7) TMI 7 - BOMBAY High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=38363</link>
      <description>The proviso to section 13 of the Indian Income-tax Act, 1922 could not support an addition unless the Revenue proved that the assessee-company itself accrued or received the alleged income. The Tribunal found no evidence that the company received amounts beyond the contractual prices, and no nexus was shown between any alleged manipulation by managing agents and the company&#039;s actual receipts. The question whether excess income had been received was treated as one of fact, and the factual finding was that no such income accrued or was received by the assessee-company. The disputed addition was therefore not justified and the Tribunal&#039;s deletion was upheld.</description>
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      <pubDate>Thu, 01 Jul 1976 00:00:00 +0530</pubDate>
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