In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed
Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)
Charitable Trust (2022) 450 ITR 368 (Mad) (HC ) iii) Bachittar Singh vs. CIT 2010 (AIR 328ITR400)(P&H HC) iv) Roshan Lal Sanchiti vs PC IT 2023 452ITR229 (SC) Further, surrender is also based on incriminating material, which has been found and seized from a premise covered under search. Non deposit of post dated cheques does not tantamount to retraction