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2014 (5) TMI 231 - GUJARAT HIGH COURTRestriction of disallowance u/s 37(1) of the Act – Held that:- CIT(Appeals) followed the judgement of the same assessee delivered by the Tribunal - the assessee had advertised the exchange offer in the newspaper and the commission earned from ICICI Bank was also disclosed - Out of the total number of persons to whom discount was offered, some of them also had given notarised affidavit - it directed to treat only the part of income as unexplained expenses - both the CIT(A) and the Tribunal adjudged the issue based on factual matrix – thus, no substantial question of law arises for consideration – Decided against Revenue.
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