Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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ITAT held that an assessment selected for limited scrutiny on cash deposits could not be widened to examine other bank credits or treat them as business receipts without the mandatory administrative approval and intimation required under CBDT instructions. Because the AO went beyond the flagged issue without jurisdiction, the assessment was set aside. On merits, amounts transferred by partners from their own bank accounts and reflected in their capital accounts were accepted as partners' deposits, not the firm's business income, since the partners had disclosed those sums in their individual returns and no material showed that the receipts belonged to the firm.
ITAT held that an assessment selected for limited scrutiny on cash deposits could not be widened to examine other bank credits or treat them as business receipts without the mandatory administrative approval and intimation required under CBDT instructions. Because the AO went beyond the flagged issue without jurisdiction, the assessment was set aside. On merits, amounts transferred by partners from their own bank accounts and reflected in their capital accounts were accepted as partners' deposits, not the firm's business income, since the partners had disclosed those sums in their individual returns and no material showed that the receipts belonged to the firm.
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