Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (6) TMI 1030 - AT - Income TaxAssessment proceedings u/s 153C - unexplained share capital - addition made on protective basis - Settlement Commission has not admitted the application of the assessee on the grounds that the assessee does not qualify as a “related” person to the “specified person”- HELD THAT:- Addition was confirmed in the hands of other Assessees and not on the assessee here in by the settlement Commission, the protective assessment made in the hands of the assessee does not survive. Addition on substantive basis, as incriminating material found during the search is pertaining to Assessment Year 2010-1 and not pertaining to Assessment Year 2009-10, further, even before us the Revenue has not refuted the finding of the Ld. CIT(A). As relying on of Sinhgad Technical Education Society case [2017 (8) TMI 1298 - SUPREME COURT], we find no error or infirmity in the order of the CIT(A) in deleting the addition and find no merit in the grounds of Appeal of the Revenue.
|