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2020 (12) TMI 385 - AT - Income TaxReopening of assessment u/s 147 - salary paid to the assessee along with other two persons was found recorded in seized documents, which was not recorded in the books of accounts of the said company - HELD THAT:- On the very same documents, the additions have been made in assessment years 2009-10 in 2010-11 respectively in the case of the assessee. In the case of the Modern Dairy Ltd., the addition was made for salary expenditure incurred out of the books of accounts, whereas in the case of the assessee addition has been made for salary received and not reported in the return of income. In our opinion, when the very basis of the addition made has been deleted by the Tribunal, the addition made on the basis of those documents in the case of the assessee cannot survive. Accordingly, we delete the additions in assessment years 2009-10 and 2010-11 respectively. The grounds of both the appeals of the assessee are accordingly allowed.
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