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2021 (10) TMI 448 - AT - Income TaxAddition u/s 68 - accommodation entries in the shape of share premium obtained - Protective assessment - Income is taxable in whose hands? - The sole purpose of all the entities manage and controlled by the Employee of the main accused was to provide accommodation entries to various outside entities/persons. There was no actual business activities in any of the entity manage and controlled by such employee - HELD THAT:- The revenue is not very clear as to whom the amounts have been attributed and tax is to be collected. The ld. CIT (A) has also not given in any categorical finding as to which entity is the real owner of the amount. Hence, the matter is being remanded back to the file of the ld. CIT (A) to pass an order by giving a categorical finding on the assessability of the income. Appeal of the assessee is allowed for statistical purpose.
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