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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.
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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