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2016 (6) TMI 697 - GUJARAT HIGH COURT

2016 (6) TMI 697 - GUJARAT HIGH COURT - TMI - Addition on account of interest income on alleged advances treating the same as accrued interest -ITAT deleted the addition - Held that:- The entire issue is based on appreciation of evidence on record. On the basis of the available material, the Tribunal found no justification for sustaining the addition. In fact, there was no reliable material for making the additions. Issue being predominantly in the realm of appreciation of evidence, no interfere .....

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made by the AO of ₹ 5,93,265/- on account of interest income on alleged advances treating the same as accrued interest ? 2. We have perused the material on record with the assistance of the learned counsel for the Revenue. Issue pertains to charging of interest of alleged advances made by the assessee. The Assessing Officer calculated the rate of return at compounded 18% on the basis of the seized documents during search. The Assessing Officer discarded the explanation of the as .....

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whose English translation is available on page no.29 to 63 of the paper book. The search team has nowhere confronted the assessee specifically with these two pages. A vague question under question no.28 has been asked. The question is Today during the course of search proceedings from your house loose paper/documents as per file no. AS-5 page no.1 to 108 are found, which have been seized which are having page no.1 to 108. You check it one by one. I am showing serial wise, explain the .....

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