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Assesee has raised the ground that CIT(A) grossly erred in sustaining the huge and arbitrary addition on sales to sister concerns on a selective picking of data and representing the difference between cost and selling price and terming it as an apparent loss under no commercial compulsion in the absence of a cogent finding by Assessing Officer to this effect.

Shanti Prime Publication Pvt. Ltd.

Section 28(i) of the Income-tax Act, 1961—Income from business- Addition on account of under pricing was not warranted as there was no revenue yield to the recipient sister concern and so, under pricing was done to reduce tax incidence and assessing officer missed the vital point that income was below taxable limit after b/f losses were set off during the current year, moreover, there was no finding by the lower authorities that sister concerns benefited in any manner - PRATAP (R.) V/s ASSTT. CIT - [2020] 183 ITD 750 (ITAT-COCHIN)

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