Client Code Modification: ITAT Deletes Addition Over Unsubstantiated Shareholding

Sahil Satishbhai Shah Vs ITO (ITAT Ahmedabad)

In a recent judgment, the Income Tax Appellate Tribunal (ITAT), Ahmedabad bench, has set aside an addition of Rs. 2,53,000 made against an individual taxpayer, Sahil Satishbhai Shah, for the Assessment Year 2012-13. The case revolved around alleged “client code modification” (CCM) involving shares of C. Mahendra Ltd, which the tax authorities had treated as unexplained cash credit under Section 68 of the Income-tax Act, 1961.

The dispute originated when the Assessing Officer (AO) reopened Mr. Shah’s tax assessme

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