BRR ( India ) Pvt Ltd v. ITO ( 2021) The Chamber’s Journal -March -P.188 (Bang ) (Trib)

S. 28(i): Business income – AIR information- Addition cannot be made solely on the basis of AIR information . [ S.145, From No .26AS ]

Allowing the appeal of the assessee the Tribunal held that only on the basis of AIR information reflected in Form No 26AS  of the assessee   addition cannot be made . Followed  Arati Raman v . DCIT ( ITA No  245 /Bang / 2012  dt 5-10-2012 ) in which  FAQ and press release it has been stated that no addition can be made only on the basis  of AIR.  On the facts  since the assessee reconciled the difference  addition made  solely on the basis of  information reflected  in AIR was deleted . ( ITA No. 10/ Bang / 2019 dt 20 -2 -2019) ( AY. 2009 -10)