2024 (11) TMI 153

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....rounds of appeal: 1. On the facts and in the circumstances of the case and in law, the ld. CIT(A) erred in deleting the addition of Rs.1,37,09,672/- under section 69C of the Income Tax Act, 1961 on account of alleged commission income, by holding that the addition was not made on the basis of any incriminating material found during the course of search proceedings in the case of Oneworld Group, without appreciating the fact that addition on the issue of commission income was already made in the order u/s. 153A of the Act, and the addition made u/s. 153C of the Act was merely rectification of mistake apparent from record. 3. Brief facts of the case are that the assessee is a public limited company engaged in manufacturing of yarn and had ....

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....(3) for A.Y. 2018-19 where the ld. A.O. made various additions including addition u/s. 69C of the Act towards commission paid on alleged accommodation entries on sales and purchases @ 3% of the said transaction. The ld. A.O. then passed the impugned assessment order dated 15.03.2022 u/s.153C of the Act, determining the total income at Rs.507,17,51,030/-, after making an addition on the balanced figure, which was missed out while assessing the total income of the assessee u/s.144 r.w.s. 153A of the Act towards bogus purchases and sales amounting to Rs.45,69,89,091/- at 3% of the said amount, aggregating to Rs.1,37,09,672/-. 4. Aggrieved the assessee was in appeal before the first appellate authority, challenging the assessment order. 5. Th....