The key person of the group managed all financial affairs and he was responsible for earning the undisclosed income emerged from the seized materials, all the transactions, which did not belong to any specific group were to be considered in his hands. Therefore, the Order of CIT(A) was to be set aside and the issues restored to the Assessing Officer for fresh adjudication after considering the order passed by Settlement Commission.(AY. 2017 -18)
Shiv Cotex India P. Ltd. v. Dy. CIT [2024] 109 ITR 594 (Delhi)(Trib)
S. 143(3): Assessment -Search – Income to be taxed in the hands of key person- Matter remanded.[S. 132, 153A]