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Merely because the assessee had erroneously offered a particular sum for taxation, the Revenue cannot take advantage of the ignorance of the assessee and bring to tax a receipt which is outside the ambit of definition of “income” under the Act. While so stating in (2020] 19 ITR (Trib)-OL 299 (ITAT[Mum])the tribunal held that the decision of the hon’ble Supreme Court in the case of Goetze India Ltd. does not apply to Tribunal. In this case the assessee wrongly offered interest on tax-free bonds to tax.

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