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2014 (7) TMI 206 - AT - Income TaxUnderstatement of income or not - less booking of maturity value of Certificate of deposits – Held that:- The assessee explained that it had sold the deposits prematurely in the secondary market, so that there is no basis for assuming the assessee to have realized a total of ₹ 42.09 cr., as assumed by the AO - even though there was a dispute in relation to the deposits, it is related to the return of the securities held with the custodian and it did not impact the accrual of income arising on the deposits, which had been accounted for from year to year - The book value of the deposits, accordingly, as on 31.03.1997 stood at ₹ 40.16 cr - assessee have realized ₹ 41.05 cr. on the sale of the securities during the relevant previous year - the excess stands accounted for as income for the current year, i.e., by way of interest for the period 01.04.1997 to the date of sale (Rs.70.54 lacs) and profit on sale of securities (Rs.18.30 lacs) – there was no case for suppression or understatement of income having been made out by the Revenue – thus, there is no infirmity in the order of the CIT(A) – Decided against Revenue.
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