This weekly round-up analytically summarizes the key stories related to the Income Tax Appellate Tribunal (ITAT) reported at Taxscan.in during the previous week from June 11 to June 17, 2022
Yuvraj Singh vs ITO – 2022 TAXSCAN (ITAT) 751
The Income Tax Appellate Tribunal (ITAT), Delhi bench has held that since the income tax is collected through the “Vivad Se Viswas Scheme” ended the litigation, penalty under section 271B of the Income Tax Act, 1961 will not sustain.
Progressive Poultry Farm vs Income Tax Officer – 2022 TAXSCAN (ITAT) 503
The Visakhapatnam bench of the Income Tax Appellate Tribunal (ITAT) has held that drawings made for non-business purposes are not allowable as a deduction under section 36(1)(iii) of the Income Tax Act, 1961
Anisha R. Dhanan vs A.C.I.T – 2022 TAXSCAN (ITAT) 750
The Income Tax Appellate Tribunal (ITAT), Ahmedabad bench held that details in return of income which are not correct, filed by the assessee shall be treated as inaccurate particulars.
Hashesh V.Patel (HUF) vs The ITO – 2022 TAXSCAN (ITAT) 753
The Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) has imposed a cost of Rs. 5,000 for the negligent attitude during the income tax proceedings.
Indian Redcross Society vs The ITO – 2022 TAXSCAN (ITAT) 754
The Income Tax Appellate Tribunal (ITAT), Ahmedabad bench sets aside addition towards ‘Anonymous Donations’ thereby granting relief to the Indian Red Cross Society.
Vinayna Veljee vs ITO – 2022 TAXSCAN (ITAT) 756
The Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) has held that the assessee is entitled to deduct the proportionate principal amount paid for obtaining the 1st instalment on the maturity of the LIC policy under the provisions of the Income Tax Act, 1961.
Aditya Saraf HUF vs ITO – 2022 TAXSCAN (ITAT) 752
The Delhi bench of the Income Tax Appellate Tribunal (ITAT)has upheld an addition of long-term capital gain by observing that the assessee has failed to explain the reason for the increase in shares. The department earlier found that the share price has increased due to price manipulation and rigging using a penny stock company.
Shri Chandrakant L. Patel vs DCIT – 2022 TAXSCAN (ITAT) 727
The Ahmedabad Bench of Income Tax Appellate Tribunal (ITAT) has held that a null and void transfer of land does not form capital gain and additional short-term capital gain was not sustainable.
Prathamesh Developers vs ITO – 2022 TAXSCAN (ITAT) 757
The Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) has held that amount once included and taxed by a partner can’t be added to the taxable income of the firm. The Tribunal observed that. K.R. Bora, an individual, had included Rs.28.35 lakh in his own hands and paid taxes and can take remedial action for exclusion of said amount from his total income as per law.
The A.C.I.T. vs Shri Rameshbhai Jivrajbhai Desai – 2022 TAXSCAN (ITAT) 758
If the assessment order passed under Section 153A was held to be void ab initio, penalty on the additions does not survive, so was held by the Income Tax Appellate Tribunal (ITAT), Ahmedabad. The Appeal has been preferred by the revenue against the order passed by CIT in favour of the assessee.
The National Anti-Profiteering Authority (NAA), has held that M/s Total Environment Habitat Pvt. Ltd has not passed the benefit of additional ITC available after the introduction of GST on ‘construct service toe’to the purchaser and found guilty of anti-profiteering. The Authority observed that the project was approve to the introduction of GST by the competent authority.
O3 Capital Global Advisory Pvt. Ltd vs Deputy Commissioner of Income-tax – 2022 TAXSCAN (ITAT) 759
The Bangalore Bench of Income Tax Appellate Tribunal has held that the assessee fails explain in the drastic decreasing of the share rate from Rs.5.6 Crore to Rs.15 lakhs and holds transaction as bogus and uphold disallowance of short-term capital loss. The Tribunal observed that the purchase and sale of shares are arranged transactions to create bogus short term capital loss in the garb of real transactions with the short-term capital lots to evade tax.
Sant Tukaram Sahakari Sakhar Karkhana Ltd. vs ITO – 2022 TAXSCAN (ITAT) 714
The Income Tax Appellate Tribunal (ITAT), Pune bench has held that additional purchase price fixed for sugarcane under clause 5A of Control Order not allowed as deduction. It was concluded that the difference between the price paid as per clause 3 of the Control Order, 1966 determined by the Central Government and the price determined by the State Government under clause 5A of the Control Order, 1966, was like `distribution of profits‟ and hence not deductible as expenditure.an
Gujarat Smelting & Refining Co. Ltd. vs ITO – 2022 TAXSCAN (ITAT) 760
The Ahmedabad bench of Income Tax Appellate Tribunal has upheld the Income Tax Penalty for setoff of business loss by showing bogus transactions. The Tribunal observed that the primary onus lies upon the assessee to furnish the basic documentary evidence in support of the particulars shown by it in the income tax return but the assessee fails to do so.
Shri Baljeet Yadav vs The PCIT – 2022 TAXSCAN (ITAT) 761
Quashing a revision order passed under section 263 of the Income Tax Act, 1961, the Income Tax Appellate Tribunal (ITAT), Jaipur bench has held that the scope of limited scrutiny is confined to its purpose and such an assessment cannot be treated as “erroneous” to invoke revisional jurisdiction.
Shri Jitendra Manilal vs ITO – 2022 TAXSCAN (ITAT) 749
The Income Tax Appellate Tribunal (ITAT), Ahmedabad bench held that to consider share transaction as business income “the quantum of profit made from sale higher than dividend earned by taxpayers. The Tribunal observed that the CIT (A) has erred in facts and law in holding that the loss of the rom sale of shares was short-term capital losses and hence not eligible a for deduction against income from the profession of the assessee.
Nekkanti Sea Foods Limited vs Principal Commissioner of Income Tax – 2022 TAXSCAN (ITAT) 746
The Income Tax Appellate Tribunal (ITAT), Vishakhapatnam bench held that export entitlements (MEIS) and duty drawback of promotion scheme is income assessable under “profits or gains from business or profession. The Tribunal observed that the export entitlements (MEIS) and the duty drawback of promotion scheme is an income assessable under the head “profits or gains from business or profession” as per clause (iiib) and (iiid) to section 28 of the IT Act, 1961.”
Global Waste Management Cell Pvt. Ltd vs Centralised Processing Centre – 2022 TAXSCAN (ITAT) 691
The Income Tax Appellate Tribunal (ITAT), Mumbai bench set aside disallowance made by Assessing Officer (AO) on the ground that late deposit of employees contribution of PF but before the due date of filing of return of income.
Late Sh. Krishan Kumar Modi vs Assistant Commissioner of Income Tax –2022 TAXSCAN (ITAT) 763
The Income Tax Appellate Tribunal, Delhi Bench has held that no penalty u/s 271 AAA(1) if the assessee offered undisclosed income in the statement recorded u/s 132(4) is and ready to pay tax with interest. The Tribunal observed that the penalty under section 271AAA(1) cannot be imposed in a case where the assessee has offered the undisclosed income in the statement recorded under section 132(4) of the specify which how such income has been derived and if the assessee pays the tax along with interest of such income.
M/s Wyeth Ltd vs Asst. Commissioner of Income Tax – 2022 TAXSCAN (ITAT) 682
The Mumbai bench of the Income Tax Appellate Tribunal (ITAT) has held that deduction u/s 80IB can be disallowed for the sale of scrap generated during the manufacturing process. The Tribunal directed the assessee to submit the details of expenses within 60 days and the Assessing Officer to decide the issue of disallowance after considering the details.
Meghmani Energy Ltd vs The DCIT – 2022 TAXSCAN (ITAT) 755
The Income Tax Appellate Tribunal (ITAT), Ahmedabad bench held that where an asset purchased by the assessee has been used in business and included in ‘block of asset’, depreciation to be allowed. The Tribunal observed that merely because there was no manufacturing activity in the relevant previous year, that could not be reason enough conclusion that unabsorbed appreciation of assessee in earlier years was not entitled to be set off against its business income in the current year.
Ramanlal Jawanmal Shah vs ACIT-CPC – 2022 TAXSCAN (ITAT) 762
The Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) held that the interest income received on maturity of Government bonds cannot be taxed in the year of accrual only for the reason that the debtor bank has deducted TDS on the entire interest amount at the time of payment on a cash basis, and the same would amount to double taxation.
Nadiadwala Grandson Entertainment Pvt. Ltd vs DCIT – 2022 TAXSCAN (ITAT) 764
In a major relief to Nadiadwala Grandson Entertainment Pvt. Ltd, owned by Sajid Nadiadwala, the Mumbai bench of the Income Tax Appellate Tribunal (ITAT) has allowed a claim of consideration paid towards the sale remake rights of Telugu movie ‘Varsham’ remade as ‘Baaghi’ in Bollywood.
The Assistant Commissioner of Income Tax vs Rohan & Rajdeep Infrastructure – 2022 TAXSCAN (ITAT) 765
The Pune bench of the Income Tax Appellate Tribunal (ITAT) has held that the depreciation under section 32 of the Income Tax Act, 1961 is allowable on toll collection rights as the same would be treated as a ‘capital asset’.
Bhikhabhai Ambalal Patel vs Income Tax Officer – 2022 TAXSCAN (ITAT) 662
The Ahmedabad Bench of Income Tax Appellate Tribunal has allowed an appeal against imposing penalty u/s 271(1)(c) without specifying the reason for imposing penalty. It was observed that the notice under Section 274 read with Section 271(1)(c) of the Act has also not revealed the proper limb of invocation of Section 271(1)(c) penalty.
Barapur Gramodyog Vikas Samiti vs ITO – 2022 TAXSCAN (ITAT) 663
The Delhi Bench of Income Tax Appellate Tribunal has held that assessee could not be penalized by denying the exemption for a mere technical violation an allowing exemption u/s 10(23B). It was observed that the reason for denying the exemption by the AO is that the Commission has given certificate sale to the assessee for more than three years.
Mrs Spureet Kaur Neg vs ACIT – 2022 TAXSCAN (ITAT) 685
The Mumbai bench of the Income Tax Appellate Tribunal ITAT while considering a bunch of appeals has held that addition u/s 69B will sustain when the authenticity of the gift received was proven with corroborative evidence. The Tribunal observed that if the Revenue authorities had any evidence to prove the cash withdrawn has been used by the assessee then the subsequent redeposit in cash cannot be denied.
Kyal Agencies Private Limited vs Principal Commissioner of Income Tax-1 – 2022 TAXSCAN (ITAT) 677
The Cuttack Bench of Income Tax Appellate Tribunal has held that primary addition to income by AO was deleted on appeal, no correction of an arithmetical mistake by invoking sec 263 survive. The Tribunal observed that the issue of genuineness, creditworthiness and identity of the sundry creditors, the same has already been filed before the CIT(A) abased on of the remand proceedings, the CIT(A) has deleted the substantial portion of the addition resulting into the sustenance of addition of Rs.11,375/- only.
Rane Industries Pvt. Ltd vs DCIT – 2022 TAXSCAN (ITAT) 767
The Income Tax Appellate Tribunal (ITAT), Pune bench has held that a bonafide and inadvertent mistake ultimately caused an excessive claim of the deduction would not attract penalty under section 271(1)(c) of the Income Tax Act, 1961.
The DCIT vs Shri Goverdhan Prasad Singhal – 2022 TAXSCAN (ITAT) 766
The Income Tax Appellate Tribunal, Jaipur Bench has upheld allowing deduction u/s 54F for purchased new house property since residential house properties are shown as stock in trade in books of account. The Tribunal observed that the other residential houses are unsold properties of the trading business of the appellant and the appellant himself has reflected the seven residential house properties as stock in trade in his books of account.
The DCIT vs Shri Goverdhan Prasad Singhal – 2022 TAXSCAN (ITAT) 766
The Income Tax Appellate Tribunal ( ITAT ), Jaipur Bench has been directed to adopt actual sale consideration instead of stamp duty value for calculating Capital gain tax. The Coram observed that if the objection is made by the assessee for value taken, the Assessing Officer ought to have refer the matter to the Valuation Officer as per section 50C(2) to ascertain fair Market value.
Haldex India Pvt. Ltd vs DCIT – 2022 TAXSCAN (ITAT) 768
The Pune Bench of Income Tax Appellate Tribunal has held that subsidy received by assessee under Package Scheme of Incentives is a capital receipt and not chargeable to tax. The Tribunal observed that the relevant consideration should be the purpose of subsidy and not its source or mode of payment.
Col. D. Pradeep Kumar vs DCIT – 2022 TAXSCAN (ITAT) 771
The Chennai bench of the Income Tax Appellate Tribunal ( ITAT ), in a significant ruling has held that service tax is not payable until consideration was received. It was observed that the assessee was following an exclusive method to account for Service Tax liability in the Books of Accounts and the argument that the Service Tax was not routed through the profit & Loss Account would not stand.
Nitin Madhukar Rathi vs Dy. Commissioner of Income Tax – 2022 TAXSCAN (ITAT) 770
The Pune Bench of Income Tax Appellate Tribunal ( ITAT ) has held that no evidence was adduced to prove the creditworthiness of creditors and confirms addition made by CIT (A).
Kendrapara Credit Co Society Ltd vs Income Tax Officer – 2022 TAXSCAN (ITAT) 769
The Income Tax Appellate Tribunal (ITAT), Cuttak bench has held that the penalty under section 271B of the Income Tax Act, 1961 cannot be levied for delay in filing of audit report due to statutory auditors.
Neelam Dhingra vs DCIT – 2022 TAXSCAN (ITAT) 776
Re assessment order passed by the Assessing Officer (AO) was quashed by the Income Tax Appellate Tribunal (ITAT), Delhi on the ground that Income Tax Notice sent to Dead Person is invalid. The re-assessment order passed under invalid notices for to reopen assessment and for the assumption of jurisdiction for carrying out the assessment is thus apparently bad in law and has no legal sanctity.
Rahul M. Vadodariya vs ITO – 2022 TAXSCAN (ITAT) 773
The assessee, Rahul M. Vadodariya, preferred an appeal before the Income Tax Appellate Tribunal (ITAT), Ahmedabad against the order of the Commissioner of Income Tax (CIT) passed for the assessment year 2011-12. ITAT directed fresh adjudication as there was a delay in filing an appeal by the assessee due the to default of the assessee’s employee.
Suncap Commodities Private Limited vs The Dy. Commissioner of Income-tax – 2022 TAXSCAN (ITAT) 779
The Mumbai Bench of Income Tax Appellate Tribunal has held that amounts credited in books of accounts lack genuineness and upholds addition made u/s 68. The Tribunal observed that the assessee executed a tripartite agreement and took the responsibility of the loan of Stephens financial services private limited and Manali properties and finance private limited from Dunlop India Ltd and Falcon tyres Ltd respectively without any consideration or placing any security.
Vipul Dilipbhai Shah vs DCIT Central Circle-2(3)2022 TAXSCAN (ITAT) 781
The Income Tax Appellate Tribunal ( ITAT ), Mumbai Bench has held that income tax liability won’t arise for unsecured loan transactions done by group entities. It was observed that the recipient of the loans was M/s. Greenbird (Rs.50 lacs) and M/s. P.D. Constructions (R$.3.42 CRS.) and not the assessee.
Shri Vrajeshkumar N. Chokshi vs Income Tax Officer – 2022 TAXSCAN (ITAT) 778
The appeal has been filed by the assessee, Vrajeshkumar N. Chokshi, before the Income Tax Appellate Tribunal (ITAT), Ahmedabad against the order of the Commissioner of Income-Tax (CIT). The ITAT held that reopening of assessment on the ground that assessee had earned LTCG from the entire value of share transactions is liable to be quashed.
Muralikrishna Vaddi vs ACIT/DCIT – 2022 TAXSCAN (ITAT) 780
The Visakhapatnam bench of the Income Tax Appellate Tribunal (ITAT) has observed that to avail the deduction of foreign tax credit, it is mandatory to file the statement in Form-67 on or before the income tax due date.
Mihir Madhavrao Suryawanshi vs ITO – 2022 TAXSCAN (ITAT) 735
Penalty cannot be levied for mere deletion of Capital Gain Exemption Claim under Section 54F of the Income Tax Act,1961 and so was held by Income Tax Appellate Tribunal (ITAT), Pune. The Bench observed ”that this Tribunal’s co-ordinate Bench has already deleted the foregoing 54F disallowance and therefore, we conclude that the penalty in issue herein has no legs to stands as a necessary corollary.”
Shri Yagnesh Dayabhai Vyas vs Income Tax Officer – 2022 TAXSCAN (ITAT) 775
The Income Tax Appellate Tribunal (ITAT), Ahmedabad held that disallowance under Section 40(a)(ia) cannot be made when established that payee has offered income on interest payment made by appellant.
Shri Ravindra Dattu Jadhav vs The Income Tax Officer – 2022 TAXSCAN (ITAT) 774
The Income Tax Appellate Tribunal (ITAT), Pune bench has held that the addition of undisclosed income will sustain unless transaction details of refund made by customer were furnished. It was observed that the sale bills of agricultural produce were furnished before the AO and was held that the bills were obtained from the non-existent merchant.
Lalitadevi N. Tibrewala vs Pr. Commissioner of Income Tax – 2022 TAXSCAN (ITAT) 772
Conditions for revision under Section 263 are not fulfilled hence Income Tax Appellate Tribunal (ITAT), Ahmedabad set asides order as there is no prejudice to interest of revenue. The Assessing Officer (AO) without carrying out the necessary verification on this aspect has allowed the claim of the assessee in the assessment framed under section 143(3) of the Act. Thus, the assessment order was held by the PCIT under section 263 of the Act as erroneous insofar prejudicial to the interest of revenue. Aggrieved by the order of PCIT the assessee is before the Tribunal.
Chirai Salt (India) Pvt vs D.C.I.T – 2022 TAXSCAN (ITAT) 782
The Income Tax Appellate Tribunal Ahmedabad Bench has held that minor adjustments made to valuation of goods not amount to under-valuation of stock. The Tribunal find that the entire exercise by the Revenue authorities, treating the stock of raw material and finished goods of the assessee as under-valued is totally arbitrary, without any basis and highly immaterial, considering the adjustment made to the valuation of these goods to the extent of 3% and 8% only which is too minor to hold that the assessee had attempted any under-valuation of stock.
Garg Acrylics Ltd. vs Addl. CIT, Special Range-4 – 2022 TAXSCAN (ITAT) 783
The Delhi bench of Income Tax Appellate Tribunal has deleted addition based on statement of witnesssince revenue fails to provide cross-examination of material witness. The Tribunal observed that the appellant is entitled to cross-examine Shri Bhatia for a just and fair decision making.
Balani Infotech P. Ltd Vs ACIT – 2023 TAXSCAN (ITAT) 692
The Income Tax Appellate Tribunal (ITAT) Delhi bench held that reasonableness of expenses to be judged from the angle of the businessman rather than from the angle of Assessing Officer (AO).
M/s Tristar Container Services (Asia) Pvt. Ltd vs Assistant Commissioner of Income Tax – 2022 TAXSCAN (ITAT) 790
The Income Tax Appellate Tribunal (ITAT), Chennai bench has held that the amount of payment of lease rental cannot be treated as Revenue expenditure as the assessee’s claim for depreciation was allowed by the income tax department and as per the agreement it was not clear as to whether the same is a finance lease or operating lease.
Kalpesh Kashiram Patel vs Income Tax Officer – 2022 TAXSCAN (ITAT) 786
The Income Tax Appellate Tribunal (ITAT), Ahmedabad bench has held that the filing of an appeal, which is defective is merely a technical breach. Condoning the delay, the Tribunal has directed the assessee to file a fresh appeal online after rectifying the errors and directed the Commissioner of Income Tax (Appeals) to adjudicate the same afresh.
Rajendra Venkat Reddy vs Asstt. Commissioner of Income-tax – 2022 TAXSCAN (ITAT) 791
Condonation on delay in filing an appeal in the absence of sufficient cause was dismissed by the Income Tax Appellate Tribunal (ITAT), Pune bench. The Tribunal comprise Shri R S Syal, Vice President and Partha Sarathi Chaudhury, JM observed that the assessee has not given any genuine reasons for the delay in filing the appeal and held that the delay of 1103 days cannot be condoned simply because of the reasons that the assessee was confused regarding the course of action which he was supposed to take.
M/s. Om Balaji Stores vs ITO – 2022 TAXSCAN (ITAT) 792
The Chennai bench of the Income Tax Appellate Tribunal (ITAT) has held that the cash payments made to suppliers cannot be disallowed by invoking section 40A(3) of the Income Tax Act, 1961 by observing that the assessee has proved the genuineness of the payments and the existence of the suppliers.
Aadhar Stumbh Township Pvt.Ltd. vs Commissioner of Central Excise & Central Goods & Service Tax Commissionerate – 2022 TAXSCAN (CESTAT) 331
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Chennai bench has held that limitation is not applicable to refund retained by the service tax department having the nature of revenue deposit. Anil Choudhary, member (judicial) observed that the refund application was filed within the limitation as prescribed under Section 102(3) of the Finance Act and the service tax deposited by the appellant has taken the changed character of revenue deposit, by operation of law as the Government of India extended exemption with retrospective effect vide notification no.9/2016-ST read with Section 102 introduced by Finance Act, 2016.
ACIT, Circle-2(1) vs Smt B. Sujata Subudhi – 2022 TAXSCAN (ITAT) 787
The Cuttack Bench of Income Tax Appellate Tribunal has held that no estimation of gross profit without rejection of books of account u/s 145(3). The Coram of Mr. George Mathan, Judicial Member and Mr. Arun Khodpia, Accountant Member has held that “the assessment order clearly shows that the provisions of section 145 (3) have not been invoked and the books of account of the assessee have not been rejected. This being so, admittedly, estimation of the assessee’s income is not permissible. In these circumstances, we find no reason to interfere with the order of the ld CIT(A)”.
Roop Fashion vs The DCIT – 2022 TAXSCAN (ITAT) 789
The Income Tax Appellate Tribunal, Chandigarh Bench has held that addition of part of cash deposit to total Income on surmises and conjectures and upholds the deletion of addition u/s 69A. The Coram of Mr. N.K.Saini, VPandMr. Sudhanshu Srivastava, JM has held that “the addition of Rs. 97,50,000/- made by the AO on the basis of surmises and conjectures was rightly deleted by the CIT(A). We do not see any valid ground to interfere with the detailed and logical findings given by the CIT(A) in the impugned order”.
Bombay Real Estate Development Co. P. Ltd vs Income Tax Officer – 2022 TAXSCAN (ITAT) 784
Re-Assessment cannot be made without fresh information regarding Escapement of Income so was held by Income Tax Appellate Tribunal (ITAT), Mumbai. Pramod Kumar, Vice President and Sandeep Singh Karhail, Judicial Member observed “As is evident from the facts available on record, no new information was received by the Assessing Officer at the time of initiation of reassessment proceedings, and it was merely a fresh application of mind to the same set of facts as were available at the time of original scrutiny assessment proceedings. Thus, in view of the above, we are of the considered opinion that the reopening of assessment under section 147 of the Act, in the present case, is bad in law and therefore is set aside.”
Foot Mart Retail India Pvt.Ltd vs ACIT – 2022 TAXSCAN (ITAT) 694
The Income Tax Appellate Tribunal (ITAT), New Delhi bench has held cessation of liability u/s41(1) not charged even in the absence of write off of outstanding liabilities in books of account. The Tribunal held that the revenue failed to establish that the assessee had obtained any benefit of reduction in the earlier years of such liabilities by way of their remission or cessation and upheld the order.
Zodiac Transport Co.Pvt. Ltd vs ACIT – 2022 TAXSCAN (ITAT) 623
The Income Tax Appellate Tribunal (ITAT), Delhi bench consisting of Saktijit Dey, Judicial Member, and Pradip Kumar Kedia, Accountant Member held that the onus of establishing creditworthiness and genuineness of transactions is on the assessee under Section 68 of Income Tax Act.
Sh. Jai Parkash Garg vs Pr. CIT – 2022 TAXSCAN (ITAT) 788
The Delhi Bench of Income Tax Appellate Tribunal has held that Principal Commissioner of Income Tax (PCIT) fails to mention as to how assessment order was erroneous and prejudicial to interest of revenue and set asides order issued u/s 263.
Maninagar Co.Op. Bank Ltd. vs DCIT – 2022 TAXSCAN (ITAT) 793
The Ahmedabad bench of Income Tax Appellate Tribunal (ITAT) has held that depreciation claimed for the Government securities categorised as AFS is allowable. It was observed that the appellant all the investments are in AFS category and observed that records of the securities about the categories to which it relates have to be maintained.
Support our journalism by subscribing to Taxscan AdFree. Follow us on Telegram for quick updates.
