Failure Of Assessee To Give Proper Reasons For Not Appearing Before The Tax Authorities: ITAT Imposes Cost
2 years, 6 months ago

Failure Of Assessee To Give Proper Reasons For Not Appearing Before The Tax Authorities: ITAT Imposes Cost

Live Law  

The Banglore Bench of the Income Tax Appellate Tribunal consisting of B.R. Baskaran has imposed a cost of Rs.10,000 on the assessee for the failure to give proper reasons for not appearing before the tax authorities. The ITAT noted that CIT had passed the ex-parte order without hearing the assessee since the assessee had not appeared before him despite being given several opportunities. "Since the assessee has not afforded proper reasons for not appearing before the tax authorities, I am of the view that the assessee shall be imposed cost. Accordingly, I impose a cost of Rs.10,000, which shall be paid to the credit of the Income Tax Department within one month from the date of receipt of this order by the assessee as other fees," the tribunal ordered.

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History of this topic

Grants For Daily Expenses Are Not Consideration For Services Rendered By Assessee, Not Liable To Tax: Kerala High Court
4 weeks ago

Grants For Daily Expenses Are Not Consideration For Services Rendered By Assessee, Not Liable To Tax: Kerala High Court

Live Law  

The Kerala High Court stated that financial grants provided to the assessee for covering daily operational expenses do not qualify as payment for any services that the assessee might be providing and are not liable to tax. The Bench of Justice Gopinath P. observed that “The assessee has only received grants to meet its day-to-day expenses including salary, allowances etc. …

Grants For Daily Expenses Are Not Consideration For Services Rendered By Assessee, Not Liable To Tax: Kerala High Court
4 weeks ago

Grants For Daily Expenses Are Not Consideration For Services Rendered By Assessee, Not Liable To Tax: Kerala High Court

Live Law  

The Kerala High Court stated that financial grants provided to the assessee for covering daily operational expenses do not qualify as payment for any services that the assessee might be providing and are not liable to tax. The Bench of Justice Gopinath P. observed that “The assessee has only received grants to meet its day-to-day expenses including salary, allowances etc. …

AO Can't Disregard ITAT's Direction To Re-examine Issue By Referring To CBDT Circular: Delhi High Court
4 months, 3 weeks ago

AO Can't Disregard ITAT's Direction To Re-examine Issue By Referring To CBDT Circular: Delhi High Court

Live Law  

The Delhi High Court has held that the assessing officer cannot disregard the direction of the Income Tax Appellate Tribunal to re-examine the issue by referring to the circular issued by the Central Board of Direct Taxes.The bench of Justice Yashwant Varma and Justice Ravinder Dudeja has observed that since the additional grounds had come to be accepted by the …

I-T Authority Fails To Consider Reason For Difference In Sale Consideration & Stamp Duty: Mumbai ITAT Deletes Penalty Levied U/s 270A For Under-Reporting Of Income
7 months, 2 weeks ago

I-T Authority Fails To Consider Reason For Difference In Sale Consideration & Stamp Duty: Mumbai ITAT Deletes Penalty Levied U/s 270A For Under-Reporting Of Income

Live Law  

Noting that neither the Assessing Officer nor the CIT have taken into consideration the explanation offered by the Assessee during the assessment proceedings in relation to the difference in the sale consideration and the stamp duty valuation of immovable property, the Mumbai ITAT deleted the penalty levied u/s 270A of the Income tax Act for under-reporting of income. Accordingly, the …

Assessee Is Eligible For Credit Of TCS Paid U/S 194Q If There Is No Shortfall In Payment Of TDS: Vishakhapatnam ITAT
7 months, 3 weeks ago

Assessee Is Eligible For Credit Of TCS Paid U/S 194Q If There Is No Shortfall In Payment Of TDS: Vishakhapatnam ITAT

Live Law  

On finding that there is no short fall of TDS and the assessee is eligible to get credit of the entire amount, the Visakhapatnam ITAT directed the AO to grant credit of the entire amount deducted as tax at source u/s. The Bench noted that Kaccha Arahtias turnover includes only the gross commission and not the sales effected on behalf …

Penalty Order On Ground Of Misreporting Of Income Not Justified When SCN And Assessment Order Alleged Under-Reporting: ITAT
7 months, 3 weeks ago

Penalty Order On Ground Of Misreporting Of Income Not Justified When SCN And Assessment Order Alleged Under-Reporting: ITAT

Live Law  

The Hyderabad Bench of Income Tax Appellate Tribunal has held that the penalty order on the ground of misreporting of income was not justified when show cause notice and the assessment order alleged under-reporting.The bench of Laliet Kumar has observed that once the assessee himself admitted the fact that there was under-reporting of income, which was also accepted. The Hyderabad …

Taxpayer Must Substantiate Form 26AS Or Form 16 So As To Claim Credit Over TDS: Mumbai ITAT
8 months, 3 weeks ago

Taxpayer Must Substantiate Form 26AS Or Form 16 So As To Claim Credit Over TDS: Mumbai ITAT

Live Law  

While remanding the case back for re-adjudication, the Mumbai ITAT held that the prima facie onus would be upon the Assessee to substantiate its claim of non-granting of TDS credit, by providing relevant documents, such as an appointment letter, salary slips or Form No.16 or bank statements, or any other corroborative evidence/ documents. The Bench of the ITAT comprising of …

Taxpayer Can't Be Penalised For Failure To Get Its Books Of Accounts Audited If There Exists Reasonable Cause For Such Failure: Jaipur ITAT
9 months, 1 week ago

Taxpayer Can't Be Penalised For Failure To Get Its Books Of Accounts Audited If There Exists Reasonable Cause For Such Failure: Jaipur ITAT

Live Law  

While allowing the appeal against the order passed u/s 271B of the Income tax Act, the Jaipur ITAT held that provision of section 273B gives power to the taxing authority not to impose the penalty if the assessee proves that there was a reasonable cause for failure to get the books of accounts audited and directed the AO to delete …

Ahmedabad ITAT Quashes Reopening In Absence Of Tangible Material With AO To Form Reason To Believe Escaped Assessment
9 months, 1 week ago

Ahmedabad ITAT Quashes Reopening In Absence Of Tangible Material With AO To Form Reason To Believe Escaped Assessment

Live Law  

The Ahmedabad ITAT quashed reopening proceedings finding that there was no tangible material available with the AO to form a reason to believe that the income of assessee has escaped assessment. The Bench of Waseem Ahmed and Siddhartha Nautiyal observed that “simply that Shri Prakash bhai Ishwar bhai Changela and the assessee are maintaining the bank account in the Social …

No Question Of Invoking Sec 201(1)/201(1A) if Taxpayer Has Deducted TDS At Appropriate Rates: Rajkot ITAT
10 months, 2 weeks ago

No Question Of Invoking Sec 201(1)/201(1A) if Taxpayer Has Deducted TDS At Appropriate Rates: Rajkot ITAT

Live Law  

Noting that assessee has also furnished tabular chart along with supporting documents to demonstrate that TDS at appropriate rates has been deducted on such trade discount / commission given to it's agents, the Rajkot ITAT held that assessee cannot be held as in default for not deducting TDS. The Division Bench of Waseem Ahmed & Siddhartha Nautiyal observed that “the …

Income Tax Authorities Can’t Step Into Shoes Of Businessmen To Determine Expenditure For Business Purpose: ITAT
1 year, 1 month ago

Income Tax Authorities Can’t Step Into Shoes Of Businessmen To Determine Expenditure For Business Purpose: ITAT

Live Law  

The Delhi Bench of Income Tax Appellate Tribunal has held that income tax authorities cannot step into the shoes of businessmen to determine how much expenditure should have been incurred for the purpose of business.The bench of Astha Chandra and B. R. R. Kumar has observed that activities clearly demonstrate that the assessee had incurred expenses. The Delhi Bench of …

Tax Cases Weekly Round-Up: 1 To 7 October, 2023
1 year, 2 months ago

Tax Cases Weekly Round-Up: 1 To 7 October, 2023

Live Law  

Delhi High Court Case Title: PCIT Versus Pepsico India Holding Pvt. Case Title: Booking.Com India Support & Marketing Services Private Limited Versus DCIT The Mumbai Bench of Income Tax Appellate Tribunal has held that the arm's-length price of the employee stock option plan expenses cannot be taken as ‘Nil’. CESTAT Case Title: M/s Punjab Cricket Association Versus The Commissioner of …

Income Tax Act; Mere Uploading Of Notice On Assessee’s E-Portal Is Not Proper Service: ITAT
1 year, 3 months ago

Income Tax Act; Mere Uploading Of Notice On Assessee’s E-Portal Is Not Proper Service: ITAT

Live Law  

The Chandigarh Bench of the Income Tax Appellate Tribunal has held that mere uploading of notice on the assessee’s e-Portal of the Income Tax Department is not proper service as per the Income Tax Act.The bench of Sanjay Garg and Vikram Singh Yadav has observed that service of notice on the portal alone without compliance with Section 282 of. The …

ITAT Imposes Cost Of Rs.10K On Foreign Portfolio Investor For Not Responding To Section 142(1) Notices
1 year, 4 months ago

ITAT Imposes Cost Of Rs.10K On Foreign Portfolio Investor For Not Responding To Section 142(1) Notices

Live Law  

The Mumbai Bench of the Income Tax Appellate Tribunal has imposed a cost of Rs.10,000 on a foreign portfolio investor for not responding to notices under Section 142 of the Income Tax Act.The bench of Vikas Awasthy and Padmavathy has observed that there is negligence on the part of the assessee in not responding to the notices issued by. The …

Income Would Accrue Only When The Assessee Gets A Right To Receive The Income: ITAT
1 year, 4 months ago

Income Would Accrue Only When The Assessee Gets A Right To Receive The Income: ITAT

Live Law  

The Bangalore Bench of the Income Tax Appellate Tribunal has held that the income would be receivable only when the income accrues to the assessee, and the income would accrue to the assessee only when the assessee gets such a right to receive the income.The bench of George George K. and Laxmi Prasad Sahu has observed that the assessee would …

ITAT Disallows Interest Paid On Loan Taken For Paying Compensation To Family Members Pursuant To Arbitral Award On Family Settlement
1 year, 5 months ago

ITAT Disallows Interest Paid On Loan Taken For Paying Compensation To Family Members Pursuant To Arbitral Award On Family Settlement

Live Law  

The Panaji Bench of the Income Tax Appellate Tribunal has disallowed the interest paid on a loan that was taken for paying compensation to the assessee’s family members pursuant to an arbitral award on family settlement.The bench of R.S. The Panaji Bench of the Income Tax Appellate Tribunal has disallowed the interest paid on a loan that was taken for …

Additions Can’t Be Made In Absence Of Incriminating Material: ITAT Deletes Income Tax Addition
1 year, 6 months ago

Additions Can’t Be Made In Absence Of Incriminating Material: ITAT Deletes Income Tax Addition

Live Law  

The Mumbai Bench of the Income Tax Appellate Tribunal has held that the additions could not have been made in the absence of any incriminating material.The bench of Kavitha Rajagopal and B.R. Baskaran observed that the additions made by the Assessing Officer under Section 68 of the Act towards the sale of shares and also estimated. The Mumbai Bench of …

Department Can Bring Expenditure Incurred In Earlier Years To Be Taxed In Subsequent Years On Grounds Of Bogus Expenditure: ITAT
1 year, 7 months ago

Department Can Bring Expenditure Incurred In Earlier Years To Be Taxed In Subsequent Years On Grounds Of Bogus Expenditure: ITAT

Live Law  

The Delhi Bench of the Income Tax Appellate Tribunal has observed that the department can bring expenditures incurred in earlier years to be taxed in subsequent years on grounds of bogus expenditure.The bench of B. R. R. Kumar has observed that the department can bring the expenditure incurred in the earlier years to be taxed in the subsequent years if …

Non-Compete Fee Related To Profession Is Made Taxable Only w.e.f. AY 2017-18: ITAT
1 year, 8 months ago

Non-Compete Fee Related To Profession Is Made Taxable Only w.e.f. AY 2017-18: ITAT

Live Law  

The Delhi Bench of the Income Tax Appellate Tribunal has held that a non-compete fee related to a profession is made taxable only with effect from AY 2017–18, and the non-compete fee in relation to a profession for periods prior to AY 2017–18 would be treated as a capital receipt.The bench of Astha Chandra and Shamim Yahya has decided in …

In Absence Of Proper Show Cause Notice To The Assessee, There Is No Merit In Levy Of Penalty: ITAT
1 year, 8 months ago

In Absence Of Proper Show Cause Notice To The Assessee, There Is No Merit In Levy Of Penalty: ITAT

Live Law  

The Delhi Bench of the Income Tax Appellate Tribunal has held that where the initiation of penalty is one limb and the levy of penalty is another limb, then in the absence of proper show cause notice to the assessee, there is no merit in the levy of penalty.The bench of Anil Chaturvedi and Yogesh Kumar Us has relied on …

NFAC Bound By The Decision Of Jurisdictional High Court: ITAT
1 year, 9 months ago

NFAC Bound By The Decision Of Jurisdictional High Court: ITAT

Live Law  

The Bangalore Bench of the Income Tax Appellate Tribunal has held that the National Faceless Appeal Centre was bound by the binding decision of the jurisdictional high court, where the AO was situated.The two-member bench of N.V. Vasudevan and Laxmi Prasad Sahu has observed that an appeal against the decision of the Agra ITAT would be before. The Bangalore Bench …

Appearance Of AR Not Enough For Presuming Service On Assessee Under S. 292BB Of ITA: Orissa High Court
1 year, 10 months ago

Appearance Of AR Not Enough For Presuming Service On Assessee Under S. 292BB Of ITA: Orissa High Court

Live Law  

The Orissa High Court has deprecated the Income Tax Authority who, despite being informed that the assessee was in judicial custody, failed to serve a notice upon him through the Superintendent of the concerned jail, in the proceedings initiated against the assessee under Section 263 of the Income Tax Act, 1961. The Court further ruled that appearance of the authorized …

Merely Making Unsustainable Claim Will Not Amount To Furnishing Of Inaccurate Particulars Of Income: ITAT
1 year, 10 months ago

Merely Making Unsustainable Claim Will Not Amount To Furnishing Of Inaccurate Particulars Of Income: ITAT

Live Law  

The Pune bench of the Income Tax Appellate Tribunal has held that the mere making of a claim, which is not sustainable by the law itself, will not amount to furnishing inaccurate particulars of income.The bench of S.S. Vishwanethra has observed that the appellant cannot be held guilty of furnishing inaccurate particulars of income, and, therefore, the Assessing. The Pune …

ITAT Sustains Disallowance As Cash Payment Exceeds Rs. 20,000 To Single Party In Single Day
1 year, 11 months ago

ITAT Sustains Disallowance As Cash Payment Exceeds Rs. 20,000 To Single Party In Single Day

Live Law  

The Chennai Bench of the Income Tax Appellate Tribunal has sustained the disallowance under section 40A of the Income Tax Act as a cash payment exceeds INR 20,000 to a single party in a single day.The two-member bench headed by Mahavir Singh and G. Manjunatha has observed that Section 40A, which has been amended w.e.f. The Chennai Bench of the …

Tax Cases Weekly Round-Up: 04 December To 10 December 2022
2 years ago

Tax Cases Weekly Round-Up: 04 December To 10 December 2022

Live Law  

Supreme Court Case Title: State of Jharkhand and others Versus Linde India Limited and Another The Supreme Court has held that the main function of oxygen in manufacturing steel is to reduce the carbon content; therefore, it can be considered a refining agent but not a raw material, so the concessional rate of sales tax is not available on oxygen. …

Tax Cases Monthly Round-Up: November, 2022
2 years ago

Tax Cases Monthly Round-Up: November, 2022

Live Law  

Indirect Taxes Supreme Court Case Title: OCL India Limited vs State of Orissa Citation: 2022 LiveLaw 911 The Supreme Court upheld States' power to impose entry tax from Industrial Township/Areas. Bombay High Court Case Title: Asit C. Mehta Financial Services Limited versus The Customs Excise and Service Tax Appellate Tribunal The Bombay High Court has ruled that the time limit …

Department Is Not Allowed To Travel Beyond The Issues Involved In Limited Scrutiny Cases: ITAT
2 years ago

Department Is Not Allowed To Travel Beyond The Issues Involved In Limited Scrutiny Cases: ITAT

Live Law  

The Delhi Bench of the Income Tax Appellate Tribunal has held that the department is not allowed to travel beyond the issues involved in limited scrutiny cases.The two-member bench of N.K. The Delhi Bench of the Income Tax Appellate Tribunal has held that the department is not allowed to travel beyond the issues involved in limited scrutiny cases. The assessee …

Filing Of Form 10–IC Is Mandatory Condition To Claim The Benefit Of Reduced Corporate Tax Rate For The Domestic Companies: ITAT
2 years ago

Filing Of Form 10–IC Is Mandatory Condition To Claim The Benefit Of Reduced Corporate Tax Rate For The Domestic Companies: ITAT

Live Law  

The Mumbai Bench of the Income Tax Appellate Tribunal has held that in order to claim the benefit of a reduced corporate tax rate, domestic companies have to mandatorily file Form 10–IC.The two-member bench of Sandeep Singh Karhail and Om Prakash Kant has observed that the assessee did not file Form 10–IC before the due date of filing the return. …

Income Tax Assessment made by a non-jurisdictional officer is void: Kolkata ITAT
2 years, 1 month ago

Income Tax Assessment made by a non-jurisdictional officer is void: Kolkata ITAT

Live Law  

The Kolkata Income Tax Appellate Tribunal has held that the income tax assessment made by a non-jurisdictional officer is null and void.The two-member bench of Sonjoy Sarma and Rajesh Kumar has observed that in the case of a non-corporate assessee in non-metro cities, the ITR filed up to Rs. The Kolkata Income Tax Appellate Tribunal has held that the income …

Expenses Towards Advertisement, Brokerage And Commission, Incurred By A Real Estate Developer; Deductible As Revenue Expenditure: Delhi High Court
2 years, 1 month ago

Expenses Towards Advertisement, Brokerage And Commission, Incurred By A Real Estate Developer; Deductible As Revenue Expenditure: Delhi High Court

Live Law  

The Delhi High Court has ruled that The bench of Justices Manmohan and Manmeet Pritam Singh Arora observed that the dispute involving the year of deduction, which was sought to be postponed by the revenue department, was revenue neutral, having no tax affect and that it did not put the revenue department at any disadvantageous position. The Court noted that …

Tax Cases Weekly Round-Up: 9 October To 15 October, 2022
2 years, 2 months ago

Tax Cases Weekly Round-Up: 9 October To 15 October, 2022

Live Law  

Supreme court Case Title: Tata Motors Limited Versus Central Sales Tax Appellate Authority & Others Citation: 2022 LiveLaw 847 The Supreme Court has directed the state of Andhra Pradesh to transfer to Jharkhand the amount of central sales tax deposited by Tata Motors with respect to the sale of buses to the Andhra Pradesh State Road Transport Corporation. Versus Commissioner …

Non-Existence Of Parties Who Gave Loan To Assessee Is Indication Of Its Prima Facie Bogus Nature: ITAT
2 years, 4 months ago

Non-Existence Of Parties Who Gave Loan To Assessee Is Indication Of Its Prima Facie Bogus Nature: ITAT

Live Law  

The Delhi Bench of the Income Tax Appellate Tribunal has held that the non-existence of the parties who have given loans to the assessee is a clear indication of their nature being prima facie bogus. The Assessing Officer issued summons to several parties at the address provided by the assessee requesting their personal deposition and information. During the analysis of …

Tax Cases Monthly Round-Up: July 2022
2 years, 4 months ago

Tax Cases Monthly Round-Up: July 2022

Live Law  

Indirect Tax Supreme Court Case Title: Commissioner of Customs And Central Excise, Amritsar v. M/s. Madras High Court Case Title: M/s.Anantham Retail Private Limited Versus State Tax Officer Citation: 2022 LiveLaw 283 While quashing the assessment order, the Madras High Court held that a demand for GST, interest, and penalty on Form DRC-01A cannot be made without the issuance of …

Twin Conditions In Section 10B (8) Income Tax Act Has To Be Fulfilled To Claim Exemption Relief: Supreme Court
2 years, 5 months ago

Twin Conditions In Section 10B (8) Income Tax Act Has To Be Fulfilled To Claim Exemption Relief: Supreme Court

Live Law  

For claiming the benefit under Section 10B of the Income Tax Act, the twin conditions of furnishing a declaration before the assessing officer and that too before the due date of filing the original return of income under section 139 are to be satisfied and both are mandatorily to be complied with, the Supreme Court observed in a judgment delivered …

Expenditure Incurred After Set-Up of Business Is Allowable As Deduction, Even If No Business Income Is Earned By The Assessee : ITAT Chennai
2 years, 5 months ago

Expenditure Incurred After Set-Up of Business Is Allowable As Deduction, Even If No Business Income Is Earned By The Assessee : ITAT Chennai

Live Law  

The Chennai Bench of ITAT has ruled that once the business of an assessee is set-up, all the expenditure incurred by it would be allowable as deduction, notwithstanding the fact that no business income was earned by the assessee during the relevant year. The assessee RBL Hotels submitted before the ITAT that it had duly set-up its business during the …

Other Income Tax Additions In Reassessment Proceedings Cannot Be Sustained If Addition on Primary Grounds Is Not Made: ITAT
2 years, 6 months ago

Other Income Tax Additions In Reassessment Proceedings Cannot Be Sustained If Addition on Primary Grounds Is Not Made: ITAT

Live Law  

The Delhi Bench of the Income Tax Appellate Tribunal consisting of C.N. The assessee/appellant has challenged the validity of the assessment made by the Assessing Officer as the assessment was reopened for escapement of income on account of cash deposits made into the bank account by the assessee. The reasons recorded by the Assessing Officer have reason to believe that …

Setting Aside Of Assessment Orders By ITAT On Technical Grounds Will Not Lead To Automatic Quashing Of Criminal Complaint: Madras High Court
2 years, 6 months ago

Setting Aside Of Assessment Orders By ITAT On Technical Grounds Will Not Lead To Automatic Quashing Of Criminal Complaint: Madras High Court

Live Law  

The Madras High Court recently held that when an assessment order is quashed by the Income Tax Appellate Tribunal on technical grounds, the same cannot be made a ground to evade criminal prosecution before the concerned court under the Income Tax Act. ii)The assessment order passed by the Assessing Officer, confirmed by the CIT have been set aside by the …

Weekly Round Up Of Tax Cases : 1 May To 7 May, 2022
2 years, 7 months ago

Weekly Round Up Of Tax Cases : 1 May To 7 May, 2022

Live Law  

Supreme Court Supreme Court Saves Over 90,000 Income Tax Reassessment NoticesIssued After 2021 Amendment By Deeming Them As Notices Under Section 148A Case Title: Union of India v. Ashish Agarwal Citation : 2022 LiveLaw 444 The Supreme Court, on Wednesday, directed that reassessment notices under Section 148 of the unamended Income Tax Act which were issued beyond 01.04.2021 to be …

ITAT Final Arbiter Of Facts, Its Order Can Be Interfered With Only If There Is Substantial Question Of Law, Manifest Illegality/ Perversity: Delhi HC
2 years, 7 months ago

ITAT Final Arbiter Of Facts, Its Order Can Be Interfered With Only If There Is Substantial Question Of Law, Manifest Illegality/ Perversity: Delhi HC

Live Law  

Observing that the Income Tax Appellate Tribunal is the final arbiter of the facts, the Delhi High Court has observed that the High Court can interfere with its order only if there is substantial question of law or there is manifest illegality or it suffers from perversity.Justice Manmohan and Justice Dinesh Kumar Sharma was dealing with an appeal challenging the …

Additions Cannot Be Made To Assessee's Income On Basis Of Document Declared By The CESTAT As 'Dumb Document': Ahmedabad ITAT
2 years, 7 months ago

Additions Cannot Be Made To Assessee's Income On Basis Of Document Declared By The CESTAT As 'Dumb Document': Ahmedabad ITAT

Live Law  

The Ahmedabad Bench of ITAT has ruled that additions cannot be made to assessee's taxable income under the Income Tax Act, 1961 on the basis of documents that are declared as 'dumb documents' by the CESTAT in the service tax proceedings before it. The Assessee Rajesh Sajjanraj Bafna submitted before the ITAT that additions were made by the authorities on …

Non Production Of Persons Despite Summons Leads To Inference Of Routing Own Money : ITAT Delhi
2 years, 9 months ago

Non Production Of Persons Despite Summons Leads To Inference Of Routing Own Money : ITAT Delhi

Live Law  

The Delhi Bench of ITAT, consisting of members G.S. Pannu and K. Narsimha Chary, has ruled that an Assessing Officer has the power to verify transactions beyond the paperwork submitted by the Assessee under Section 68 of the Income Tax Act, 1961. The Assessing Officer had disallowed expenses and made additions to Assessee's income under Section 68 of Income Tax …

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