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The ITAT dismissed revenue appeals concerning alleged suppression of sales and inflated commission expenditure. Regarding sales suppression, the Tribunal found the addition unjustified as the AO failed to establish how electronic sales could be deposited into separate bank accounts, never provided IATA data to the assessee for verification, and misunderstood Agency Debit Memo as income rather than expense. The AO relied solely on an appraisal report without independent investigation or providing computation methods. Concerning commission expenditure, the ITAT upheld CIT(A)'s deletion of additions, noting the AO arbitrarily set 10% as reasonable without justification, failed to challenge payment genuineness, and disregarded business prudence from the assessee's perspective as established in Dhanrajgiri Raja Narasingirji.
The ITAT dismissed revenue appeals concerning alleged suppression of sales and inflated commission expenditure. Regarding sales suppression, the Tribunal found the addition unjustified as the AO failed to establish how electronic sales could be deposited into separate bank accounts, never provided IATA data to the assessee for verification, and misunderstood Agency Debit Memo as income rather than expense. The AO relied solely on an appraisal report without independent investigation or providing computation methods. Concerning commission expenditure, the ITAT upheld CIT(A)'s deletion of additions, noting the AO arbitrarily set 10% as reasonable without justification, failed to challenge payment genuineness, and disregarded business prudence from the assessee's perspective as established in Dhanrajgiri Raja Narasingirji.
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