<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2023 (11) TMI 1142 - ITAT MUMBAI</title>
    <link>https://www.taxtmi.com/caselaws?id=446251</link>
    <description>The ITAT Mumbai held that the assessee, who voluntarily offered commission income claiming involvement in accommodation entries, cannot selectively treat only Rs. 87 lakhs as tainted while asserting other transactions as genuine. Since the assessee failed to prove genuineness of unsecured loans beyond book entries, all transactions were deemed accommodation entries rather than legitimate share trading. The tribunal directed that commission income should be estimated based only on debit entries (outward remittances) not credit entries, as credits represent layered funds while debits represent actual accommodation provided. The matter was remanded to AO for quantification based on bank statements, with directions that if higher commission income is determined or bank statements aren&#039;t provided, the original assessment stands confirmed.</description>
    <language>en-us</language>
    <pubDate>Wed, 20 Sep 2023 00:00:00 +0530</pubDate>
    <lastBuildDate>Wed, 29 Nov 2023 06:47:00 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=733273" rel="self" type="application/rss+xml"/>
    <item>
      <title>2023 (11) TMI 1142 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=446251</link>
      <description>The ITAT Mumbai held that the assessee, who voluntarily offered commission income claiming involvement in accommodation entries, cannot selectively treat only Rs. 87 lakhs as tainted while asserting other transactions as genuine. Since the assessee failed to prove genuineness of unsecured loans beyond book entries, all transactions were deemed accommodation entries rather than legitimate share trading. The tribunal directed that commission income should be estimated based only on debit entries (outward remittances) not credit entries, as credits represent layered funds while debits represent actual accommodation provided. The matter was remanded to AO for quantification based on bank statements, with directions that if higher commission income is determined or bank statements aren&#039;t provided, the original assessment stands confirmed.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Wed, 20 Sep 2023 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=446251</guid>
    </item>
  </channel>
</rss>