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Judgment
This assessee’s appeal for Assessment Year 2019-20 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1083353300(1) dated 05.12.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the p arties at length. Case file perused.
Learned co unsel vehemently submits during the course of hearing that both the lower authoritie s herein have erred in law and on facts in holding the asse ssee to have availed accommodation entries to Rs.10,00,000/- from M/s Olwin Garments Pvt. Ltd. followed by entry commissio n payment thereupon @ 2%; coming to Rs.20 ,000/-, totaling to Rs.10,20,000 in issue. He has next invited the tribunal’s attention to the assessee’s detailed paper book pages 57 to 75 wherein no such loan entry could be indicated even at the Revenue’s be hest.
That being the case, t his tribunal hereby finds merit in the assessee’s instant so le substantive ground to conclude that the impugned addition of Rs.10,20,00 0/- is not sustainable in law in her hands for lack of necessary substantiation thereof. Deleted accord ingly.
This assessee’s appeal is allowed.