TaxTMI 
TaxTMI 
2025 (2) TMI 1531
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....t, Mamta Jain ("the assessee") is an individual, filed her Return of Income ("ROI") on 17.10.2016 declaring total income of Rs. 39,81,780/-. The Learned Assessing Officer ("Ld. AO") found that the assessee had credit transactions of Rs. 3,26,38,65,273/- in her bank account during A.Y. 2016-17. Therefore, he issued notice u/s.148 of the Income Tax Act, 1961 ("the Act") on 29.03.2021 and in response to the notice, the assessee declared the same income as declared in ROI dated 17.10.2016. During the assessment proceedings, the assessee submitted that the total credit of Rs. 3,26,38,65,273/- in bank account consist of Rs. 1,06,40,40,426/- on account of receipt from steel trading business and the balance of Rs. 2,19,98,24,847/- pertains to the r....
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....ed that, the assessee failed to produce licence with regards to her discounting business, invoices raised for commission received from the said business and the contract / agreement with other entities to substantiate her claim. Further there was no TDS made by the other party on the commission income of the assessee. Hence, the assessee failed to substantiate her claim and there is no infirmity in the order passed by the Ld. AO. Therefore, the Ld. DR prayed before the bench to allow the appeal of revenue. 5. Per contra, the Learned Authorised Representative ("Ld. AR") submitted that, no licence is required to carry on the discounting business. Further, he submitted that, no invoice is required to be issued for the said activity, as the ....
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....aim that the appellant was engaged in bill discounting activity and also rejecting the books and applying the GP percentage of an altogether different business activity i.e. trading in steel on the bill discounting activity cannot be sustained. The AO's action is based on conjectures and surmises. As against this, the appellant has produced irrefutable Bank Documents of bill discounting for the clients to establish the factum of carrying out the business of discounting activity. Also, the very bank account statements of the appellant itself are strong evidence that the payments made / debits were against a co-relatable credits / receipts. In the process, the bank account of the appellant is initially debited and thereafter the credits c....
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....ion related to the discounting business of the assessee and passed the order under section 143(3) of the Act accepting the discounting business of the assessee. The assessee has also accepted additional income of Rs. 22 lakhs before the Ld. AO to settle the litigation on account of credit found in the bank account and the same has been sustain by the Ld. CIT(A) also. Accordingly, the assessee has already offered Rs. 22 lakhs of additional income over and above her returned income on account her discounting business. Though it is correct that the assessee has offered the additional income of Rupees 22,00,000 before the AO however, the assessee has failed to prove to the satisfaction of the AO showing it was carry on LC discounting business a....