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    <title>2024 (11) TMI 239 - ITAT PUNE</title>
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    <description>ITAT Pune held that CIT(A) exceeded jurisdiction under section 251 by directing taxation of net profit based on a Profit and Loss Account that was never filed before the AO during assessment proceedings. The tribunal ruled that CIT(A) cannot enhance income by considering new sources of income not examined by the AO, as the AO had not applied his mind to the taxability of the impugned net profit. Following SC precedents, the tribunal directed deletion of the addition ordered by CIT(A) and allowed the assessee&#039;s appeal.</description>
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      <title>2024 (11) TMI 239 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=761253</link>
      <description>ITAT Pune held that CIT(A) exceeded jurisdiction under section 251 by directing taxation of net profit based on a Profit and Loss Account that was never filed before the AO during assessment proceedings. The tribunal ruled that CIT(A) cannot enhance income by considering new sources of income not examined by the AO, as the AO had not applied his mind to the taxability of the impugned net profit. Following SC precedents, the tribunal directed deletion of the addition ordered by CIT(A) and allowed the assessee&#039;s appeal.</description>
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