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M/S Karb Associates Pvt. Ltd., Kolkata vs D.C.I.T.,Circle-8(1), Kolkata on 25 August, 2021

In the light of the submission of the assessee on this aspect, and taking into consideration the Tribunal's decision in the case of Radhika Sales Corporation (Supra), we are of the opinion that the proviso explaining the tolerance limit has to be read retrospectively, therefore, if the difference between the declared value by the assessee and the value decided by the DVO is less than 10%, no addition is warranted. With the aforesaid observations, the issue raised by the assessee is disposed off and the A.O is directed to assess the income of the assessee as per the directions given (supra) on this issue and in accordance to law.
Income Tax Appellate Tribunal - Kolkata Cites 21 - Cited by 0 - Full Document

Dcit 10(1), Mumbai vs Star Union Dia-Ichi Life Insurance ... on 11 January, 2017

3.8. During the course of hearing before us, it has been stated by the Ld. Counsel that now the view taken by the Ld. CIT(A) has been accepted in many judgments which have been mentioned above. It is noted that in the case of Life Insurance 7 Star union Dia ichi life Corporation of India V. Addl. CIT Mumbai - (ITA NO.6221/Mum/2012 order dated 03.04.2013), the Tribunal deleted the addition made by the AO on account of Negative Reserve after making detailed analysis with the following observations:
Income Tax Appellate Tribunal - Mumbai Cites 23 - Cited by 1 - Full Document
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