No Section 56 addition When Assessee was not True Beneficiary but Only Facilitator

Sai Samarpan Realtors Pvt. Ltd. Vs ACIT (ITAT Delhi)

The case of Sai Samarpan Realtors Pvt. Ltd. Vs ACIT revolves around the initiation of proceedings under section 153C of the Income Tax Act, 1961, and subsequent additions made by the Assessing Officer (AO) under section 56 of the Act. The appeals were filed against the orders of the Commissioner of Income Tax (Appeals) [CIT(A)] dated 28.08.2023.

The primary contention raised by the assessee in ITA No. 2710/Del/2023 was that the proceedings under section 153C should not have been initiated. They argued that the initiation l

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