Guarantee Commission for TP purpose is chargeable to extent of actual exposure of facility availed

INCOME TAX : Where during search operation at premises of assessee, 288 paintings were found but Assessing Officer noted that description of paintings mentioned on vouchers given by assessee did not match and were not verifiable, since paintings were acquired by assessee in years much prior to date of search, addition in respect of said paintings could not be made in search proceedings, and, thus, it would be appropriate to restore this issue to file of Assessing Officer

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