https://www.taxtmi.com/caselaws?id=755672 The ITAT Chennai held that the AO lacked jurisdiction under section 153A to make additions regarding share capital issued by the assessee. The tribunal determined that share capital constitutes a liability, not an asset as defined under Explanation-2 of section 153A. Since the AO could only assume jurisdiction beyond the 6-year limitation period when undisclosed assets worth Rs. 50 lakhs or more escaped assessment, and share capital being a liability does not qualify as an asset, the jurisdictional requirement was not satisfied. The CIT(A)'s decision was upheld, ruling against the revenue department. en-us Wed, 10 Jul 2024 00:00:00 +0530 Wed, 17 Jul 2024 08:06:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755672 The ITAT Chennai held that the AO lacked jurisdiction under section 153A to make additions regarding share capital issued by the assessee. The tribunal determined that share capital constitutes a liability, not an asset as defined under Explanation-2 of section 153A. Since the AO could only assume jurisdiction beyond the 6-year limitation period when undisclosed assets worth Rs. 50 lakhs or more escaped assessment, and share capital being a liability does not qualify as an asset, the jurisdictional requirement was not satisfied. The CIT(A)'s decision was upheld, ruling against the revenue department. Case-Laws Income Tax Wed, 10 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755672