2025 (11) TMI 1499

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...., CIT(DR) ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)-30 [in short, the "CIT(A)"], Delhi's order dated 14.03.2023 passed in case no. 10547/2019-20, involving proceedings under section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). Heard both the part....

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....t having carried out any actual business. It seeks to buttress the point that we ought to affirm both the impugned addition(s) of the accommodation entry transactions as well as the commission income thereupon have been rightly assessed in the assessee's hands. 4. We notice at this stage that what all the lower authorities have done is to assess the assessee on "protective" basis qua both the f....