Income Surrender u/s 133A Deemed Involuntary; Additions Deleted Due to Mistaken Belief of Facts and Law.

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Full Text of the Document

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....Surrender of Income during Survey u/s 133A - Surrender is voluntary or under influence of revenue (coercion) - The retraction is supported by evidence confronted to the A.O. CIT(A) and relied upon before the ITAT remains unrebutted till date, it clearly brings out a case that the surrender was made based on facts as confronted which resulted in the action of surrender. - the surrender admittedly on facts was made on mistaken belief of facts and law and in the face of the voluminous plethora of evidences countering each of the factors considered relevant by the Revenue for addition, we have found that reliance is only placed upon statement of the Director and the employees. The additions are directed to be deleted. - AT....