Appellate Tribunal overturns income addition, ruling funds were for ultimate beneficiary, not the assessee, based on evidence.

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....Accrual of income - Addition made to the income of the assessee received by the assessee from “JDS” and its associates, treated as own income of the assessee - Despite the Department's awareness of the true nature of the transactions, the addition was confirmed by the lower authorities based on certain factors, including the deletion of similar additions in the case of the ultimate beneficiary and the appellant's previous assessment. However, the Appellate Tribunal, relying on legal precedents and the evidence presented, concluded that the funds received by the appellant were not their own income but were meant for the ultimate beneficiary. - Additions deleted.....