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2019 (5) TMI 1705 - AT - Income TaxAddition being the profits of the company on account of large-scale client code modification - HELD THAT:- Hon'ble Bombay High Court in the case of PCIT vs. PAT Commodity Services Pvt. Ltd. [2019 (2) TMI 720 - BOMBAY HIGH COURT] has dismissed the appeal filed by the Revenue against the order of the Tribunal in deleting the addition being the profits of the company on account of large-scale client code modification. Since, in the instant case, the AO has not pointed out any basis or material or evidence to support his finding that the assessee has received entry of fictitious losses and has not spelt out in the reasons recorded as well as the assessment order as to on which scrips the assessee has taken loss entries and in the order nowhere it has been mentioned of any statement of broker of the assessee regarding the admission of any fictitious client code modification, therefore, opinion that the addition made by the AO and sustained by the CIT(A) is not justified. Accordingly, the ground raised by the assessee on merit is also allowed. - Appeal filed by the assessee is allowed.
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