Addition for cash found during search cannot be made to Assessee if already offered for taxation by sister concern

Sparco Engineering Pvt. Ltd. Vs ACIT (ITAT Pune)

We find an amount of Rs.3,71,94,261/- which is above the cash receipt projected by the AO offered to tax in the hands of SMAEPL in which the assessee is sister concern, in whose hands the AO made addition again is, in our opinion, not maintainable. We note that in order to make said addition in the hands of assessee the AO relied on the same incriminating material of Page No. 21 which is not disputed by the ld. DR. However, the ld. DR, M.G. Jasnani placed on record report dated 29-03-2022 issued by the of

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