ITAT Slams Enhancement in Section 264 Proceedings – Past Salary Savings During Demonetisation Accepted

Himanshu Jain Vs ITO (ITAT Bangalore) ITAT Slams Enhancement in Section 264 Proceedings – Past Salary Savings During Demonetisation Accepted, ₹4.55 Lakh Addition Deleted The Bangalore ITAT held that proceedings under Section 264 are benevolent in nature and cannot be used by the Assessing Officer to place the assessee in a worse position than in the original assessment. In this case, the assessee had deposited ₹11.75 lakh during demonetisation and explained the source as salary received in cash over multiple years along with savings therefrom. The AO in the original assessment had al...