Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
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