Provisions of section 269ST is applicable to receiver & not to payer

Janatha Fish Meal & Oil Products Vs PCIT (ITAT Bangalore) ITAT Bangalore held that assessee has paid money for the purpose of investment which is not disputed and therefore the provisions of Section 269ST of the Act is not applicable. Facts- Post search operations and proceedings, AO concluded the assessment by accepting the return of income filed by the assessee. However, the PCIT stated that unexplained stock is offered under the head “income from other source” and not routing it through profit and loss account and therefore should be categorised as unexplained investment u/s.69C to ...