https://www.taxtmi.com/caselaws?id=760689 The MP HC dismissed revenue appeals challenging ITAT's deletion of additions made in assessee's hands for syndicate profit shares. The court held that where assessee was member of syndicates/AOPs already assessed separately under sections 144/153C read with 153A, the share of profits received by assessee after tax payment by syndicates could not be taxed again under section 86 proviso clause (a) read with section 67A. Following Supreme Court precedent in ITO vs. Ch. Achatalya, the court agreed with CIT(A) and ITAT that syndicate income should be assessed only in syndicate hands, not directly in member's hands. No substantial question of law arose under section 260-A for admission of appeals. en-us Mon, 21 Oct 2024 00:00:00 +0530 Tue, 22 Oct 2024 17:45:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760689 The MP HC dismissed revenue appeals challenging ITAT's deletion of additions made in assessee's hands for syndicate profit shares. The court held that where assessee was member of syndicates/AOPs already assessed separately under sections 144/153C read with 153A, the share of profits received by assessee after tax payment by syndicates could not be taxed again under section 86 proviso clause (a) read with section 67A. Following Supreme Court precedent in ITO vs. Ch. Achatalya, the court agreed with CIT(A) and ITAT that syndicate income should be assessed only in syndicate hands, not directly in member's hands. No substantial question of law arose under section 260-A for admission of appeals. Case-Laws Income Tax Mon, 21 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760689