No addition can be made under s 28(iv) in the absence of any business or profession relationships.

Dy. CIT v Kaizen Commercial Pvt Ltd ITAT BENCH ‘E’ MUMBAI ITA No. 5974/Mum/2005 Assessment Year: 2002-2003 Decided on: 10 June 2011 Order Per: Vijay Pal Rao, JM: This appeal filed by the revenue is directed the order dated 21.7.2005 of the CIT(A) relating to AY 2002-03. 2. The revenue has raised the following grounds: “i) The ld. CIT(A) has erred in deleting the addition of Rs. 42 crores made u/s 28(iv). ii) The ld. CIT(A) has erred in holding  that no benefit at all arose to the assessee when in fact a huge benefit has arisen which is indicated by the ever-soar...