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Income Tax - Highlights / Catch Notes

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Assessment u/s 153A - Addition of undisclosed income - Contract ...


ITAT deletes income additions u/s 153A due to lack of incriminating evidence; no substantial legal questions arise.

July 6, 2024

Case Laws     Income Tax     HC

Assessment u/s 153A - Addition of undisclosed income - Contract between assessee and non-resident entity for sharing profits from supply of currency paper to RBI - No incriminating material found during search and seizure - Agreement terminated in 2012 and assessee became non-resident from 2015-16 onwards - Receipts from foreign entities pertain to later years - Revenue unable to establish link between payments and terminated agreement - ITAT rightly deleted additions based on lack of incriminating evidence - No substantial questions of law arise.

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