In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes
Bench: Shri Manomohan Das & Shri Rakesh Mishra
section as presumed by AO has come into operation from 01-04-2017 whereas transaction relates to earlier year so it does not come within the definition of incriminating material and has no effect on determination of our taxable income. 8. That Sir, it can be looked also from another angle i.e. after initiating the proceeding what has happed