<?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>2025 (12) TMI 1688 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=784148</link>
    <description>Where the assessee admitted commission at 0.1% for providing accommodation entries but the AO applied 0.6%, the Tribunal upheld the CIT(A)&#039;s view that only the incremental 0.5% could be treated as undisclosed commission, since the admitted 0.1% was already offered; the Revenue&#039;s challenge failed. On a protective addition under s. 68, the Tribunal affirmed deletion because the AO himself accepted that the assessee merely routed funds for commission, brought no material to show the bank credits were the assessee&#039;s own assets, and did not identify any corresponding substantive addition in another case; consequently, a protective addition was impermissible. The Revenue&#039;s appeal was dismissed.</description>
    <language>en-us</language>
    <pubDate>Fri, 24 Oct 2025 00:00:00 +0530</pubDate>
    <lastBuildDate>Tue, 30 Dec 2025 09:27:34 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=874659" rel="self" type="application/rss+xml"/>
    <item>
      <title>2025 (12) TMI 1688 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784148</link>
      <description>Where the assessee admitted commission at 0.1% for providing accommodation entries but the AO applied 0.6%, the Tribunal upheld the CIT(A)&#039;s view that only the incremental 0.5% could be treated as undisclosed commission, since the admitted 0.1% was already offered; the Revenue&#039;s challenge failed. On a protective addition under s. 68, the Tribunal affirmed deletion because the AO himself accepted that the assessee merely routed funds for commission, brought no material to show the bank credits were the assessee&#039;s own assets, and did not identify any corresponding substantive addition in another case; consequently, a protective addition was impermissible. The Revenue&#039;s appeal was dismissed.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Fri, 24 Oct 2025 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=784148</guid>
    </item>
  </channel>
</rss>