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The ITAT allowed the appeal of the assessee company, holding that additions made under section 153C were unsustainable and directing deletion of the impugned additions (including Rs.25,91,654). The Tribunal found no incriminating material in the search connected to the third person and that admitted commission receipts were those of the controlling individual, not the artificial judicial person; share transfers and attendant commissions were between shareholders and did not constitute assessable income of the company. The satisfaction note was held vague and non-descriptive for lack of year-wise quantification of seized material, rendering initiation under s.153C without force of law; consequential orders under s.153C were quashed.
The ITAT allowed the appeal of the assessee company, holding that additions made under section 153C were unsustainable and directing deletion of the impugned additions (including Rs.25,91,654). The Tribunal found no incriminating material in the search connected to the third person and that admitted commission receipts were those of the controlling individual, not the artificial judicial person; share transfers and attendant commissions were between shareholders and did not constitute assessable income of the company. The satisfaction note was held vague and non-descriptive for lack of year-wise quantification of seized material, rendering initiation under s.153C without force of law; consequential orders under s.153C were quashed.
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TaxTMI 
TaxTMI 
of 4920 
