https://www.taxtmi.com/caselaws?id=439456 The Tribunal upheld the CIT(A)'s decision to delete the addition of Rs. 54,59,00,000/- on account of unexplained share capital, as the seized document did not pertain to the relevant assessment year. Additionally, the Tribunal agreed that the A.O. lacked jurisdiction to reassess based on material from a different assessment year. The protective addition was dismissed due to Settlement Commission confirmation, and the substantive addition was deemed invalid without incriminating material. The Revenue's appeal was dismissed, and the Tribunal affirmed the CIT(A)'s order on 21/06/2023. en-us Wed, 21 Jun 2023 00:00:00 +0530 Sat, 24 Jun 2023 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439456 The Tribunal upheld the CIT(A)'s decision to delete the addition of Rs. 54,59,00,000/- on account of unexplained share capital, as the seized document did not pertain to the relevant assessment year. Additionally, the Tribunal agreed that the A.O. lacked jurisdiction to reassess based on material from a different assessment year. The protective addition was dismissed due to Settlement Commission confirmation, and the substantive addition was deemed invalid without incriminating material. The Revenue's appeal was dismissed, and the Tribunal affirmed the CIT(A)'s order on 21/06/2023. Case-Laws Income Tax Wed, 21 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439456