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

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