AO not permitted to make additions beyond revision order issued u/s 263: ITAT

Brief of the Case Kolkata ITAT held In the case of Sri Manoj Murarka vs. ACIT that the AO had travelled beyond the jurisdiction vested on him by the order of the CIT u/s 263 by treating the amounts overdrawn by the son and daughter of the assessee thereby bringing the same to tax as deemed dividend. The order of CIT was restricted to the addition in hand of assessee only. Moreover both the son and daughter of the assessee are not shareholders in the lending company (BKFCPL) and hence the deemed dividend u/s 2(22) (e), if any, could be assessed only in the hands of the shareholders and not oth...