Substantive additions on protective basis: ITAT restores matter back to AO

ACIT Vs Zodiac Transport Co. Pvt. Ltd. (ITAT Delhi) In this case learned Commissioner (Appeals) had directed assessing officer to make the additions at the hands of the assessee on protective basis, since, according to him, substantive additions have to be made at the hands of the real beneficiaries i.e. the SVP Group entities. This is so because, according to learned Commissioner (Appeals), assessee is used as a mere conduit to facilitate transfer of money between the first layer of 85 companies used for parking on-money of the five flagship entities of SVP Group who are the real masterminds ...