Section 263 Revision Case: Clarifying Ownership of Undisclosed Income in Survey Proceedings u/s 69A of the Income Tax Act.

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....Revision u/s 263 - undisclosed income accepted / acknowledged by the assessee during the course of survey proceedings - There is a marked difference between “money/ cash” being “found” at the premises of the assessee and the assessee being “found” to be the “owner” of money /cash”. Section 69A of the Act only contemplates of the latter situation. - AT....