https://www.taxtmi.com/caselaws?id=762664 ITAT Rajkot allowed the assessee's miscellaneous application under Section 254(2) for mistake apparent from record. The tribunal held that when AO relies on seized documents to add undisclosed income, he must also consider undisclosed losses from the same material and allow set-off. The AO cannot selectively pick favorable portions while ignoring beneficial parts of seized documents. The tribunal directed that seized material must be read as a whole, applying "apple to apple comparison" principle. Either both undisclosed income and losses should be considered or both ignored. The AO was directed to allow set-off of undisclosed losses against undisclosed income. en-us Mon, 11 Nov 2024 00:00:00 +0530 Wed, 04 Dec 2024 11:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762664 ITAT Rajkot allowed the assessee's miscellaneous application under Section 254(2) for mistake apparent from record. The tribunal held that when AO relies on seized documents to add undisclosed income, he must also consider undisclosed losses from the same material and allow set-off. The AO cannot selectively pick favorable portions while ignoring beneficial parts of seized documents. The tribunal directed that seized material must be read as a whole, applying "apple to apple comparison" principle. Either both undisclosed income and losses should be considered or both ignored. The AO was directed to allow set-off of undisclosed losses against undisclosed income. Case-Laws Income Tax Mon, 11 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762664