ITAT Quashes Section 154 Rectification as Survey Income Character Was a Debatable Issue

Sudarshan Status Corporation Vs DCIT (ITAT Ahmedabad) The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) held that the Assessing Officer could not invoke Section 154 to reclassify income disclosed during a survey under Section 133A from business income to unexplained money under Section 69A taxable under Section 115BBE. The assessee, a real estate partnership firm, had disclosed ₹1.25 crore as additional income during a survey, explaining it as on-money receipts arising from its regular business activities. The amount was duly recorded in the books and accepted as business incom...