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ITAT Deletes ₹48.09 Lakh Addition on BSNL Receipts; Form 26AS Insufficient to Determine Income Nature

TaxGuru
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Summary

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  • The Income Tax Appellate Tribunal in Chennai has deleted a ₹48.09 lakh addition made by the Assessing Officer, ruling that Form 26AS alone cannot determine the nature of income.
  • The case involved Sri Balaji Shopping World, which argued that discrepancies in reported receipts were due to trade discounts from BSNL, not commission income.
  • The Tribunal found substantial evidence supporting the assessee's claim, including detailed reconciliations and invoice-wise documentation.
  • This ruling emphasizes that the character of receipts must reflect the underlying transactions, potentially impacting how similar cases are assessed in the future.

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