Section 292C being a deeming provision cannot be applied mechanically

Godwin Construction Pvt. Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that provisions of section 292C of the Income Tax Act is only a deeming provision and the deeming provision cannot be applied mechanically, ignoring the facts of the case and surrounding circumstances. Facts- The assessee is a company. AO has noted that a search operation was carried out at the premises of the assessee and its site office on 09.09.2010. After examination of the documents seized, notice u/s 142(1)A of the Act was issued to the assessee on 23.02.2012 calling for the return of income and in response to which, asses...