Assessing Officer Cannot Make Additions Outside Limited Scrutiny Scope Without PCIT Permission for Section 2(22)(e) Deemed Dividend

The ITAT ruled that an Assessing Officer cannot make additions outside the scope of limited scrutiny without obtaining mandatory permission from the PCIT/Pr.CIT to convert it to complete scrutiny. In this case, the AO improperly made a deemed dividend addition under section 2(22)(e) without such permission, violating binding CBDT circulars. The Tribunal held that since the addition pertained to an issue not included in the limited scrutiny parameters, it could not be sustained. The additional ground raised by the appellant was allowed, and the ITAT directed the deletion of the section 2(22)(e) addition, deciding in favor of the appellant. .....

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