No additions on account of consultancy receipts and alleged unexplained investments

Arun Madhavachari Rangachari Vs DCIT (International Taxation) (ITAT Mumbai) Conclusion: Investments made by a foreign company could not be attributed to a non-resident individual shareholder without “lifting the corporate veil.” AO could not tax these investments in the assessee’s hands without proving the funds were routed personally by him. Held:  Revenue appealed against the deletion of addition of ₹325.5 crore (out of ₹465 crore) made on protective basis in the hands of the assessee, a non-resident individual allegedly rendering consultancy services to foreign entities in relati...