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Unabated Assessment Protection: ITAT Deletes ₹6.70 Cr Share Addition; Third-Party Statement is Not Incriminating Material
Case Law Details
- Case Name
- DCIT Vs Jupiter International Limited (ITAT Kolkata)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2009-10
- Courts
- All ITAT, ITAT Kolkata
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DCIT Vs Jupiter International Limited (ITAT Kolkata)
₹6.70 Cr share application addition deleted as AY 2009-10 was an unabated year no incriminating material was found; third-party statement cannot be incriminating material u/s 153A
A search u/s 132 was conducted on Jupiter Group on 24.03.2015. For AY 2009-10, the assessment had already been completed earlier & the time limit to issue notice u/s 143(2) had expired. Hence, AY 2009-10 was an “unabated year” on the date of search.
In the original 153A/143(3) assessment, AO made an addition of ₹6,70,00,000 treating sha...
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