https://www.taxtmi.com/caselaws?id=459113 ITAT Raipur held that Rs. 1.10 crore disclosed by company directors as their undisclosed income could not be taxed in the company's hands under Section 69. The directors admitted the investment in unexplained stock/franchisee fee/furniture was sourced from their personal undisclosed income. Following the SC precedent in ITO vs. Ch. Atchaiah, the tribunal emphasized taxing the "right person" - the directors who earned the undisclosed income, not the company. However, unrecorded cash found during survey proceedings was upheld as taxable income in the company's hands due to lack of explanation. en-us Fri, 18 Aug 2023 00:00:00 +0530 Mon, 02 Dec 2024 08:53:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459113 ITAT Raipur held that Rs. 1.10 crore disclosed by company directors as their undisclosed income could not be taxed in the company's hands under Section 69. The directors admitted the investment in unexplained stock/franchisee fee/furniture was sourced from their personal undisclosed income. Following the SC precedent in ITO vs. Ch. Atchaiah, the tribunal emphasized taxing the "right person" - the directors who earned the undisclosed income, not the company. However, unrecorded cash found during survey proceedings was upheld as taxable income in the company's hands due to lack of explanation. Case-Laws Income Tax Fri, 18 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459113