AI Structured Summary
Not yet generated for this judgment
Judgment
PER SATBEER SINGH GODARA, JM:
This assessee’s appeal for assessment years 2017-18, arises against Commissioner of Income Tax (Appeals) [in short, the “CIT(A)”], Delhi-23’s order dated 22.08.2025, passed in DIN and order no. ITBA/APL/S/2025/2025-26/1079870666(1), involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case files perused.
Suffice to say, it transpires during the course of hearing at the outset that the assessee/appellant herein is aggrieved against both the learned lower authorities’ action applying the alleged commission income @ 2% on its alleged accommodation entries resulting in addition of Rs. 8,30,46,470/-; in assessment order dated 31.12.2019 as upheld in the lower appellate discussion.
That being the case, the assessee/appellant submits very fairly that it confines its challenge only to the extent of rate of the aforesaid commission component @ 2%. Mr. Singh further invites the tribunal’s attention to the Assessing Officer’s assessment order dated 21.03.2025 in the assessee’s case itself assessing the very nature of commission income @ 0.4% in the succeeding assessment year A.Y. 2018-19 which has gone unrebutted from the Revenue side. We thus deem it appropriate to direct the learned Assessing Officer to assess the assessee/appellant herein qua its commission income component in the alleged accommodation entries @0.4% in very terms followed by his consequential computation as per law.
No other ground or argument has been pressed before us.
This assessee’s appeal is partly allowed.