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2023 (7) TMI 229 - AT - Income TaxAccommodation entries received from paper companies - taxation in hands of ultimate beneficiary - maintainability of protective additions - HELD THAT:- CIT(A) in the case of present assessee had observed that M/s. Surya Processed Food Pvt. Ltd. is ultimate beneficiary and while confirming the substantial additions in hands of M/s. Surya Processed Food Pvt. Ltd. had deleted the protective additions in the hands of present assessee, the same require reconsideration on merits, in the light of orders [2019 (5) TMI 687 - ITAT DELHI] of the Tribunal wherein substantial additions in the hands of M/s. Surya Processed Food Pvt. Ltd. have also been deleted since the income has already been taxed in the hands of M/s Surya Food and Agro Limited. Ground raised by Revenue is sustained for statistical purposes and the issue is restored to the files of Ld. CIT(A) with direction to decide the issues afresh - Revenue appeal allowed for statistical purposes.
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