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Income Tax - Highlights / Catch Notes

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Assessment u/s 153A - Undisclosed cash receipts - merely because ...


Section 153A: Discrepancies in pre-search books don't justify post-search assumptions without evidence; no income extrapolation allowed.

August 24, 2021

Case Laws     Income Tax     AT

Assessment u/s 153A - Undisclosed cash receipts - merely because some discrepancies were found in assessee’s books in the pre-search period of unaccounted sales, it could not be presumed that such a discrepancy continued even in the post-search period, when there is no evidence to support such a view, and, therefore, addition could not be made on the basis that the assessee had made unaccounted sales throughout the accounting year. Being so, there is no question of extrapolation of income in all these assessment years. - AT

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