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2023 (4) TMI 1265 - ITAT DELHIAddition u/s 69 - unexplained investments made in the JP Minda Group of companies - AO made an addition on protective basis in the hands of the assessee company and the addition has been made on substantive basis in JP Minda Group Companies - HELD THAT:- Since, the substantive additions have been deleted on merits and no observation has been given that the substantive additions were deleted owing to the fact that the addition made on protective basis in the hands of the assessee company and since the assessee company has not been held to be the right assessee wherein, the substantive additions were supposed to be made by any of the authorities viz. CIT(A), co-ordinate bench ITAT, Hon’ble High Court, we hereby affirm the order of the CIT(A) Since, the appeal of the Revenue is dismissed on the core issue of taxability of the amount on the protective basis, any adjudication of the technical issues raised by the assessee under Rule 27 of ITAT Rules, 1963 becomes academic in nature.
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