2022 (10) TMI 475

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....i Himanshu Gandhi For the Respondent : Dr.Mahesh Akhade ORDER PER VIKAS AWASTHY, JM: These two appeals by the assessee are directed against the order of Commissioner of Income Tax(Appeals)-47, Mumbai [in short 'the CIT(A)'] dated 11/01/2021, common for the assessment years 2008-09 and 2009-10. 2. Shri Himanshu Gandhi appearing on behalf of the assessee submitted at the outset th....

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....n the hands of Bhanwarlal Jain Group has been confirmed by the Tribunal, protective addition in the hands of assessee be deleted. 3. Per contra, Dr.Mahesh Akhade representing the Department vehemently defended the impugned order, common for the assessment years 2008-09 and 2009-10. The ld.Departmental Representative submitted that though Tribunal has upheld the addition on account of commission....

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....als is on account of commission for providing accommodation entries. The addition has been made in the hands of assessee on protective basis, whereas, substantive addition has been made in the case of Bhanwarlal Jain Group. The Tribunal has confirmed the addition on account of commission on providing accommodation entries in the case of Bhanwarlal Jain Group. The rate of commission confirmed by th....