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2023 (8) TMI 84 - ITAT COCHINValidity of Assessment u/s 153A - deemed dividend u/s. 2(22)(e) in view of the assessee, a partner (with 40% share) in firm stands extended sums by a company in which public is not substantially interested, and of which the assessee is an Executive Director with 97% shareholding - HELD THAT:- The Revenue’s case, it’s merits apart, survives no longer in view of the decision in Abhisar Buildwell Pvt. Ltd. [2023 (4) TMI 1056 - SUPREME COURT] inasmuch as no proceedings were pending for the years under reference as on the date of search and, two, the addition/s made in the impugned assessments does not owe its origin, or is relatable, to the material found during search. Decided against revenue.
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