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ITAT held that reassessment u/s 147 was invalid as no addition was made on the very issue forming the recorded reasons, the assessee being treated instead as an accommodation entry provider with estimated commission income. Following binding HC precedent, the Tribunal ruled that additions on issues different from the recorded reasons could not be sustained, thereby allowing all six appeals on this primary ground. Additionally, on the alternative merits, ITAT directed that commission income be restricted to 0.50% on outstanding loan liabilities and 0.40% on sale-purchase transactions, and that intra-group transactions be excluded while computing commission income, granting partial relief in estimation.
ITAT held that reassessment u/s 147 was invalid as no addition was made on the very issue forming the recorded reasons, the assessee being treated instead as an accommodation entry provider with estimated commission income. Following binding HC precedent, the Tribunal ruled that additions on issues different from the recorded reasons could not be sustained, thereby allowing all six appeals on this primary ground. Additionally, on the alternative merits, ITAT directed that commission income be restricted to 0.50% on outstanding loan liabilities and 0.40% on sale-purchase transactions, and that intra-group transactions be excluded while computing commission income, granting partial relief in estimation.
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