https://www.taxtmi.com/caselaws?id=762328 ITAT Kolkata held that AO incorrectly applied Section 69C provisions to sales transactions with SINPL, which were accommodation entries rather than unexplained expenditure. Since Section 69C applies to unrecorded expenditure, not sales, the addition was legally erroneous. The tribunal directed that only profit element at 5% commission rate (Rs. 1,73,000) should be added to assessee's income instead of treating entire transaction amount as unexplained expenditure, as assessee was merely providing accommodation entries while actual purchases were made by SINPL. en-us Wed, 27 Nov 2024 00:00:00 +0530 Fri, 29 Nov 2024 08:16:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762328 ITAT Kolkata held that AO incorrectly applied Section 69C provisions to sales transactions with SINPL, which were accommodation entries rather than unexplained expenditure. Since Section 69C applies to unrecorded expenditure, not sales, the addition was legally erroneous. The tribunal directed that only profit element at 5% commission rate (Rs. 1,73,000) should be added to assessee's income instead of treating entire transaction amount as unexplained expenditure, as assessee was merely providing accommodation entries while actual purchases were made by SINPL. Case-Laws Income Tax Wed, 27 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762328