Tribunal held that the assessee demonstrated that it had included income on securitisation of housing loans in its operating income in the year when the securitisation agreement was entered into by it with the bank. No adjustments were made to its income while computing the income chargeable to tax and since complete documents were not filed by the assessee as it did not file the profit and loss account nor balance-sheets, it could not be said that the entire income arising from securitisation of the housing loan suffered taxation in the year of securitisation of the housing loan. The AO was directed to verify from the completed audited financial statements as well the computation of income whether the income from securitisation actually suffered taxation with due taxes paid by the assessee including taxability, if any of reserves for contingency as carved out by the assessee and its impact on tax payable by the assessee or whether it was tax neutral. The onus was on the AO to show that the loss claimed by the assessee was a tax evasion device adopted by the assessee. The loss had to be allowed as business loss unless the Assessing Officer was able to demonstrate that the computation of the loss was a tax evasion device, mala fide or fraud being perpetrated by the assessee to evade taxes. (AY.2011-12)