Group ITSC Findings Cannot Be Applied, U/s 153A, Subsidiary Protected

SNW Smith Consultants Pvt. Ltd. Vs ACIT (ITAT Delhi) No Incriminating Material Belonging to Assessee—153A Additions on Presumed Unbooked Commission Deleted for All AYs; ITSC Findings for Group Cannot Be Applied to Subsidiary  The Assessee, part of the Adam Smith Group (ASG), appealed against five assessments framed u/s 153A r.w.s. 143(3) for AYs 2012-13 to 2016-17. All these years were unabated assessments, and therefore additions could be made only if incriminating material belonging to the Assessee was found during search, as per the Supreme Court ruling in Abhisar Buildwell. During the s...