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 o

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