Assessment u/s 153A - Addition of bogus purchases on protective ...
Income Tax
August 24, 2021
Assessment u/s 153A - Addition of bogus purchases on protective basis in the hands of the assessee - Unless, it is brought over knowledge the fate of substantive addition in the hands of another entity, the addition in the case of the assessee cannot be sustained. In view of this we set-aside this ground of appeal back to the file of the learned assessing officer to 1st ascertain the fate of addition made on substantive basis in the hands of another entity. If the addition is sustained there on substantive basis, the addition on protective basis in the hands of this assessee deserves to be deleted. If the addition is not sustained in the hands of that assessee on its own merits, even then the protective addition cannot be sustained in the hands of this assessee. - AT
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