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2021 (6) TMI 895 - ITAT CHANDIGARHReopening of assessment u/s 147 - addition made on protective basis - investment was made in AY 2012-13 and not in AY 2011-12 - HELD THAT:- Specific paras 2(vi) to (viii) and Para 3 of the above Report clearly address the departmental position. In the light of these facts and submissions, it is deemed appropriate to allow the appeal of the assessee on the aforesaid grounds as the substantive addition has attained finality. At the same time, it is clarified that the factum of the cheque dated 31.03.2011 of ₹ 20 lacs in favour of M/s. KOC Industries Ltd. stated to be cleared in 2012-13 assessment year is kept open for consideration in the said appeal and is not being considered or decided in the present appeal as the present appeal is being decided only on the basis of the fact that substantive addition has attained finality. In the circumstances, protective addition cannot be sustained. Said order was pronounced at the time of virtual hearing itself in the presence of the parties via Webex. The appeal, accordingly, is allowed.
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