https://www.taxtmi.com/caselaws?id=782866 ITAT set aside the reassessments u/s 147 as invalid, holding that the AO recorded reasons based on alleged beneficiary status of bogus accommodation entries, but made no additions on that issue and instead taxed the assessee as an accommodation entry provider on estimated commission, contrary to the recorded reasons. Consequently, the reassessment additions could not be sustained, and all six appeals were allowed. On the alternative issue of estimation, ITAT directed that commission be restricted to 0.5% on outstanding loan liabilities at year-end and 0.4% on sale-purchase transactions, and that intra-group transactions be excluded from the commission base. en-us Wed, 19 Nov 2025 00:00:00 +0530 Fri, 05 Dec 2025 08:12:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782866 ITAT set aside the reassessments u/s 147 as invalid, holding that the AO recorded reasons based on alleged beneficiary status of bogus accommodation entries, but made no additions on that issue and instead taxed the assessee as an accommodation entry provider on estimated commission, contrary to the recorded reasons. Consequently, the reassessment additions could not be sustained, and all six appeals were allowed. On the alternative issue of estimation, ITAT directed that commission be restricted to 0.5% on outstanding loan liabilities at year-end and 0.4% on sale-purchase transactions, and that intra-group transactions be excluded from the commission base. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782866