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ITAT dismissed revenue's appeal regarding protective additions under section 68. The assessing officer alleged the assessee company acted as a conduit providing accommodation entries to beneficiaries and earned unaccounted commission. Following the precedent in Holeon Traders Pvt. Ltd., ITAT upheld deletion of protective additions made against the assessee. Regarding unaccounted commission additions, ITAT noted that while the coordinate bench initially upheld commission income additions deleted by CIT(A), a subsequent corrigendum dated 31/07/2023 clarified that CIT(A) was correct in deleting the commission income additions. Consequently, both grounds of revenue's appeal were dismissed, confirming deletion of additions made under section 68 for accommodation entries and unaccounted commission income in the assessee company's hands.
ITAT dismissed revenue's appeal regarding protective additions under section 68. The assessing officer alleged the assessee company acted as a conduit providing accommodation entries to beneficiaries and earned unaccounted commission. Following the precedent in Holeon Traders Pvt. Ltd., ITAT upheld deletion of protective additions made against the assessee. Regarding unaccounted commission additions, ITAT noted that while the coordinate bench initially upheld commission income additions deleted by CIT(A), a subsequent corrigendum dated 31/07/2023 clarified that CIT(A) was correct in deleting the commission income additions. Consequently, both grounds of revenue's appeal were dismissed, confirming deletion of additions made under section 68 for accommodation entries and unaccounted commission income in the assessee company's hands.
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