Addition u/s 28(iv) - Sweat equity shares - shares have been...

Addition u/s 28(iv) - Sweat equity shares - shares have been allotted to the appellant without any amount being paid as consideration in lieu of the appellant being an “expert” - no real income but only hypothetical income had accrued to the assessee and Section 28(iv) would be inapplicable to the facts and circumstances of the Essentially, the law evolved by the apex Court requires the Assessing Officer to be pragmatic and not pedantic. - AT