https://www.taxtmi.com/caselaws?id=755129 Delhi HC held that ITSC has jurisdiction to make additions beyond petitioner's disclosed income for commission and margin money on off-market transactions. The court ruled ITSC's power extends to issues mentioned in Commissioner's report, not just assessee's settlement application. ITSC properly considered statements from Raj Kumar Kedia and Ghansyam Das Gupta confirming 5-6% commission payments to Dhanuka Agritech Group promoters. The addition was based on evidence, not assumptions, and recorded in settlement terms. Court distinguished ITSC's settlement authority from regular assessment powers, emphasizing settlement provisions aim to resolve disputes through mutual consensus while balancing voluntary disclosure with income escaping assessment. Petition dismissed as ITSC exercised jurisdiction properly within settlement scheme's intent. en-us Wed, 03 Jul 2024 00:00:00 +0530 Fri, 05 Jul 2024 12:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755129 Delhi HC held that ITSC has jurisdiction to make additions beyond petitioner's disclosed income for commission and margin money on off-market transactions. The court ruled ITSC's power extends to issues mentioned in Commissioner's report, not just assessee's settlement application. ITSC properly considered statements from Raj Kumar Kedia and Ghansyam Das Gupta confirming 5-6% commission payments to Dhanuka Agritech Group promoters. The addition was based on evidence, not assumptions, and recorded in settlement terms. Court distinguished ITSC's settlement authority from regular assessment powers, emphasizing settlement provisions aim to resolve disputes through mutual consensus while balancing voluntary disclosure with income escaping assessment. Petition dismissed as ITSC exercised jurisdiction properly within settlement scheme's intent. Case-Laws Income Tax Wed, 03 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755129