Court held that the Tribunal had arrived at the finding of fact after considering the material evidence on record that the assessee was entitled to deduction of the contrived losses suffered by it. The Tribunal had rightly considered the fact that in the assessment for the block period only the undisclosed income, which was found from the seized material could be considered for the addition. (AY. BP 1-4-1995 to 27-9-2001)
CIT v. Naman Associates (2020) 427 ITR 91 / 273 Taxman 297 / 196 DTR 147/ 317 CTR 654(Guj) (HC)
S. 158BC : Block assessment –Undisclosed income —Reducing quantum of addition — Held to be justified [ S.158BD ]