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The ITAT dismissed the Revenue's appeal against the CIT(A)'s order deleting the cash addition in the assessee company's hands. The ITAT held that the assessee acted merely as a commission agent, and the payments related to Murlidhar Infracon Pvt. Ltd. The conveyance deeds showed that Murlidhar Infracon Pvt. Ltd. accepted making payments to farmers before its incorporation, indicating its directors/shareholders arranged the payments. No evidence suggested the payments were routed through the assessee's bank accounts. Hence, in the absence of cogent material, the ITAT upheld the CIT(A)'s findings and dismissed the Revenue's appeal.
The ITAT dismissed the Revenue's appeal against the CIT(A)'s order deleting the cash addition in the assessee company's hands. The ITAT held that the assessee acted merely as a commission agent, and the payments related to Murlidhar Infracon Pvt. Ltd. The conveyance deeds showed that Murlidhar Infracon Pvt. Ltd. accepted making payments to farmers before its incorporation, indicating its directors/shareholders arranged the payments. No evidence suggested the payments were routed through the assessee's bank accounts. Hence, in the absence of cogent material, the ITAT upheld the CIT(A)'s findings and dismissed the Revenue's appeal.
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