2026 (1) TMI 687

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....B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2018-19. 2. Brief facts of the case is that the assessee is an individual has not filed the Return of Income for the Asst. Year 2018-19, however the assessee has made substantial cash deposit of Rs. 5,73,86,000/- in his bank account maintained with Central Bank of India and also made cash withdrawal of Rs. 82,58,000/-. Hence a show cause notice u/s. 148A(b) was issued to the assessee on 20-03-2022 to make reply within seven days. Since the assessee has not complied to the show cause notice, order u/s. 148A(d) was passed on 31-03-2022 and notice u/s. 148 was issued on 04-04-2022 and duly served on the assessee. The assessee filed a belated....

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....ced in the instant case of the appellant. 5.9 It is further evident that the appellant has claimed in his submissions that the commission income in the 'Shroff business varies from 0.10% to 0.50% and as such he has earned commission income of Rs. 75,550/- and the same has been declared in the return of income. However, I opine that the percentage of commission income declared by the appellant appears to be very low in compare to the decisions cited supra, wherein, various courts have charged the said percentage @ 0.15% to 0.50% of the total credits. In regards to the chargeable percentage for commission income, Hon'ble Jurisdictional Tribunal in the case of Chintan Niketan Bhandari Vs DCIT in IT(SS)A Nos. 495 to 500 & 1604/....

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....satisfactory reply or supporting documents to establish the source of cash deposit and credit entries found in the bank account. (ii) The assessee has failed to establish the identity, genuineness and creditworthiness of the persons/entities from which cash or cheque were received. Hence, it is not established that cash or cheques received by the assessee on account of commission basis. (b) The appellant craves leave to add, alter and/or to amend all or any the ground before the final hearing of the appeal. 5. None appeared on behalf of the assessee in spite of service of notice through Department. Today is the 12th time of hearing of this appeal. Even earlier occasions notices were served through Department and Acknowl....