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2015 (4) TMI 399 - AT - Income TaxDeemed dividend u/s 2(22)(e) - assessment in pursuance of search action u/s 132(1) - addition made while passing the assessment order u/s 153A - Held that:- In this case, the assessment for the A.Ys. 2002-03 and 2004-05 had attained finality and admittedly there being no incriminating material found during the course of search relating to the addition made on account of deemed dividend, therefore, such an addition de hors any material found during the course of the search, cannot be roped in the assessment made u/s 153A by the assessing officer. Accordingly, the addition on account of deemed dividend of ₹ 1,69,68,750/- in the A.Y. 2002-03 and addition of ₹ 4,62,91,123/- on account of deemed dividend u/s 2(22)(e) is deleted as same is beyond the scope of assessment u/s 153A. - Decided in favour of assessee.
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