2022 (7) TMI 1515

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....order. 3. In ITA No. 185/Del/2020, following grounds have been raised by the assessee: "The Learned Commissioner of Income Tax Appeal have passed an erroneous and unlawful order and confirmed the additions made on basis of incorrect and false details worked out at the assessment stage and further confirmed the same. That the assessees have contested at the time of assessment. That the following account does not belong to the assessee. Sr. No. Name of Concern Account Number Name of Bank Transaction Amount/ Accommodation Entries Name of Proprietor Rate of Comm. Per lacs Amount of Commission 1 Choudhary and Co. 1552320005555 HDFC 7970056 Pankaj Tripathi 150 11955 2 Choudhary ....

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....1A) of the Act wherein the assessee has confessed that he has been operating various proprietary concerns and firms which are used to give accommodation entries to various entities. The total amount of entries given are as under: Sl. No. Assessment Year Amount of accommodation entries given 1. 2011-12 Rs.18,91,66,031 2. 2012-13 Rs.67,52,96,907 3. 2013-14 Rs.1,53,55,00,544 4. 2014-15 Rs.1,55,76,56,238 5. 2015-16 Rs.1,22,22,16,247 5. During the statement, the assessee has submitted the list of proprietary concerns and firms through which the accommodation entries have been given to various concerns which are as under: Proprietary Concerns: 1. Delhi Traders 2. ....

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....ter to the Assessing Officer to take appropriate remedial action after due verification in case of double addition on account of repeated entries. 9. The main grievance of the assessee before us are that the contra entries have not been considered and certain accounts which do not belong to the assessee have also been considered for calculation of the commission amount. 10. None appeared on behalf of the assessee. 11. The ld. DR has argued that the commission of 0.15% has been determined after taking into consideration, the multiple entries of the same amount routed through different accounts. It was argued that otherwise the normal commission rate determined by the Tribunals and High Courts in a number of cases ranged from 1.5% to....