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of The ITAT held that the CIT(A)'s enhancement under section 251(1)(a) was impermissible insofar as it sought to assess income from entirely new sources not considered by the AO during assessment; accordingly the tribunal deleted the CIT(A)'s enhancements relating to on-money payments for land purchases and additional on-money attributed to related group entities. Conversely, with respect to additions under section 2(22)(e) for intra-group payments, the ITAT found the AO's arbitrary threshold treating payments over a fixed percentage of sales as loans/advances to be unsustainable; payments shown to be in the ordinary course of business were not taxable as deemed dividends, and the CIT(A)'s deletion of those additions was upheld.
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