ITAT Delhi Judgments — December 2017

The Tribunal held that making additions on a protective basis in the hands of a shareholder when the income was already assessed substantively in the hands of the overseas companies, and no benefit was derived by the shareholder, was unwarranted. The Tribunal upheld the CIT(A)'s deletion of these additions.

The Tribunal held that making additions on a protective basis in the hands of a shareholder when the income was already assessed substantively in the hands of the overseas companies, and no benefit was derived by the shareholder, was unwarranted. The Tribunal upheld the CIT(A)'s deletion of these additions.

The Tribunal held that making additions on a protective basis in the hands of a shareholder when the income was already assessed substantively in the hands of the overseas companies, and no benefit was derived by the shareholder, was unwarranted. The Tribunal upheld the CIT(A)'s deletion of these additions.

The Tribunal restored the matter to the file of the CIT(A) for a fresh decision. The CIT(A) was directed to provide the assessee with a due and effective opportunity of hearing.