ITAT Can Holistically Evaluate Disclosures and Make Additions to Taxpayers’ Declared Income

Harsh Dhanuka HUF Vs PCIT (Delhi High Court)

Conclusion: Income Tax Settlement Commission (ITSC) had authority to make additions to the declared income of taxpayers as ITSC’s role was not confined to regular assessments but extended to holistic evaluations of the disclosures and additional income brought to its notice through settlement proceedings.

Held: Assessee filed a settlement application under Section 245D(2C). During the settlement process, a report was submitted under Rule 9 of the Income Tax Settlement Commission (Procedure)

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