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2015 (8) TMI 78 - AT - Income TaxSubstantive addition to the income u/s 158BC r.w.s. 158BD - Assessee an individual is a doctor by profession - Allegation that assessee has received substantial amount of consultation fee from the hospital - Protective assessment - Held that:- material gathered behind the assessee could not be used by the AO to make addition to the income of the assessee - The assessee had denied to have received professional fees from the hospital and based on the submissions of the assessee the AO had made addition to the income of DTHL. In our, opinion, considering the peculiar facts and circumstances of the case the FAA was not justified in confirming the addition for the AY.s. concerned. For the AY. 1995-96 addition was made by the AO on substantive basis. During the course of hearing before us, the AR stated that considering the smallness of tax effect he would not like to press the issue. Therefore, we confirm the addition made by the AO for the AY.1995-96. - Decided partly in favour of assessee.
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