Protective Addition Backfires – ITAT Says Firm Not the Earner, Partners Already Taxed

DCIT Vs Royal Developers (ITAT Jaipur)

A search was conducted in the Om Agarwal group. Loose papers were found at the residence of Shri Hemant Garg, showing year-wise figures of principal &  interest relating to Royal Developers &  Chomu House project. The AO assumed these entries represented unaccounted loans &  interest received by the firm, &  made a protective addition of ₹3.02 crore in the firm’s hands, stating that substantive additions were made in partners’ cases.

Before the CIT(A), the assessee proved that these seized papers recorded perso

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