https://www.taxtmi.com/caselaws?id=444802 ITAT Delhi upheld assessment under section 153A involving undisclosed income from trading activities. The tribunal confirmed the peak credit theory application, determining undisclosed income at Rs. 19.86 crores based on difference between receipts and payments. Property investment in individual's name was excluded from assessee's income determination. Commission income at 2% for facilitating accommodation entries was sustained as per market rates. Expenditure interpolation with unaccounted income was accepted, preventing double addition. Technical grounds regarding search and seizure were dismissed as factually established through panchnama. en-us Tue, 17 Oct 2023 00:00:00 +0530 Sat, 21 Oct 2023 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444802 ITAT Delhi upheld assessment under section 153A involving undisclosed income from trading activities. The tribunal confirmed the peak credit theory application, determining undisclosed income at Rs. 19.86 crores based on difference between receipts and payments. Property investment in individual's name was excluded from assessee's income determination. Commission income at 2% for facilitating accommodation entries was sustained as per market rates. Expenditure interpolation with unaccounted income was accepted, preventing double addition. Technical grounds regarding search and seizure were dismissed as factually established through panchnama. Case-Laws Income Tax Tue, 17 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444802