Set-Off of Losses Allowed on Survey-Declared Business Income

Tahoora Proteins Vs ITO (ITAT Ahmedabad) Excess Stock Found in Survey Is Business Income—115BBE Not Applicable for AY 2015-16- Survey Disclosure Can’t Be Branded u/s 69: Set-off of Losses Allowed by ITAT The Ahmedabad “D” Bench of the ITAT, in Tahoora Proteins vs ITO (ITA No. 1613/Ahd/2025, AY 2015-16), held that excess stock of trading goods found during survey u/s 133A constitutes business income and not unexplained investment u/s 69, and therefore tax u/s 115BBE was wrongly invoked. During survey on 02.03.2015, excess stock of Tuver Dal and packing material valued at about ₹1.20 c...