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2020 (7) TMI 433 - AT - Income TaxDeemed dividend u/s 2(22)(e) - Additions on protective basis - The appeal in the case of other assessee is pending before the Apex court - HELD THAT:- With regard to the addition of ₹ 3 Crores confirmed by the Hon’ble ITAT, Chennai M/S. SUBHAVARSHA INFOTECH [2018 (12) TMI 522 - ITAT CHENNAI] in the hands of the firm, the firm has not accepted the ITAT’s decision and has contested in appeal before the Hon’ble High Court of Madras which is pending now . In such facts and circumstances, the Ld CIT(A) ‘s decision “since the issue under consideration has not reached finality in the apex court, of the considered opinion that as of now, in view of the Hon’ble ITAT Chennai’s decision of the confirmation of addition of ₹ 4.54 Crores, the addition in the hands of the appellants - Mr.S.Sundaramoorthy and Mr.T.Padmakumaron a protective basis by the A O clearly amounts to a double addition and therefore, is unfair and unreasonable, which deserves to be deleted.” does not require any interference and hence the Revenue’s above appeals are dismissed. - Decided against revenue.
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