2025 (4) TMI 1433

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....enue : Shri Vivek Perampurna, CIT, D/R ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assessee is preferred against the order dated 07/11/2023 by NFAC, Delhi, pertaining to AY 2012-13. 2. The sum and substance of the grievance of the assessee is that the ld. CIT(A) erred in confirming the addition of Rs. 10,33,38,610/- as commission income. 3. Briefly stated the facts of the case a....

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....see stated that the said bank account was not operated by him but by Shri Raju Bhimrajka and he was given only Rs. 2,000/- per month i.e. Rs. 24,000/- per annum as commission and the same has been offered for taxation by him in his return of income. 4.1.1. The assessee was summoned u/s 131 of the Act and his statement was recorded by the AO and in his statement, the assessee categorically stated ....

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....AO was in possession of the complete information of all the three companies mentioned elsewhere. The AO was also in possession of the transactions done through RTGS inter-se bank transfers by the three companies but the AO did not make any verifications from the real culprits and taxed the entire amount in the hands of the autorickshaw driver i.e., the assessee. 8. We are of the considered view t....