2025 (5) TMI 2091

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....sment year 2018-19, stands dismissed. Vide above said assessment order, total income of the assessee was computed by the Assessing Officer as under:- Sl. No. Description Amount (in INR) 1. Income as per return of income filed 8.86.050/- 1. Income as computed u/s 143(1)(a) NA 1. Income as per return u/s 148 Not filed 1. Variation as discussed above proposed to be added u/s 69 16,80,740/- 1. Total income/loss determined as per the above proposal 25,66,790/- 2. Arguments heard. File perused. 3. As noticed above, the Assessing Officer made an addition of Rs. 16,80,740/-. On the other hand, in return of income, the assessee had declared income of Rs. 8,86,050/-. 4. Record reveals that assessment was opened u/s 147 of the Act....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....0,740/-. 7. However, the Assessing Officer was not satisfied with the reply furnished by the assessee. The Assessing Officer made an addition of the entire amount of Rs. 16,80,740/-, by observing in the manner as under:- "The assessee neither could produce details of work performed by her against which she had earned commission income neither she could furnish confirmation of account from future Maker Life Care Pvt Ltd. She also failed to submit clarification from future Maker Life Care Pvt Ltd. that payment made by them is not commission income but interest earned on investment in ponzy scheme and they have not debited the amount of Rs 16,80,740/- claiming it as expenses. In the circumstances the amount of Rs 16,80,740/- is nothing but....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... is that these entries go to show that the assessee had reflected in return of income the aforesaid amounts. When we advert to copy of notice issued under clause (b) of section 148A of the Act, it transpires that the allegation leveled by the department against the assessee was that she had shown in the return of income a sum of Rs. 14,40,000/-, as other expenses, but she had not shown in his return an income of Rs. 16,80,740/-, by way of commission received from the said company. From said particulars furnished by the assessee in the return, we find merit in the contention raised by Ld. AR for the appellant that the assessee had reflected both the amounts i.e. Rs. 14,40,000/- and Rs. 16,80,740/- in the return of income of the year under c....