The High Court dismissed the Department’s appeal, holding that no incriminating material had been brought on record by the Assessing Officer to sustain the additions on the merits, that the genuineness of the share capital and there was no live link between the seized material and the additions made, and that therefore, the assumption of jurisdiction was erroneous. SLP of Revenue dismissed. Followed PCIT v. Abhisar Buildwell P. Ltd (2023) 454 ITR 212 (SC) (AY.2010-11 to 2012-13)
PCIT (C) v. Panchmukhi Management Services Pvt. Ltd. (2023)456 ITR 358/294 Taxman 423 (SC) Editorial : PCIT v. Panchmukhi Management Services Pvt. Ltd. (2023) 456 ITR 332 / 153 taxmann.com 297 (Delhi)(HC)
S. 153C : Assessment-Income of any other person-Search-Share capital-Cash credits-Bogus accommodation entries-No incriminating material brought on record -SLP of Revenue is dismissed.[S.68, 132, 153A]