2026 (3) TMI 1397

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....espondent : Shri Nayanjyoti Nath, Sr.- AR ORDER PER SAKTIJIT DEY, VICE PRESIDENT: Captioned appeal by the Revenue arises out of order dated 09.10.2025 passed by Commissioner of Income Tax (Appeal), [CIT(A)] Mumbai for the Assessment Year (AY) 2013-14. 2. The dispute in the present appeal is confined to the solitary issue of deletion of addition of Rs. 36,35,979/-, being alleged commiss....

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....ormation, to verify the genuineness of the transactions, the Assessing Officer issued notices under section (u/s.) 133(6) of the Income Tax Act, 1961 (in short the 'Act'). However, as observed by the Assessing Officer, the notices returned back unserved. He further found that out of the sales turnover declared by the assessee more than 90% sales were made to a party, named, Viraj Profiles Limited,....

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..... Therefore, he deleted the estimation of commission of 1% on the purchase turnover. 4. So far as the estimation of commission on sales turnover, the First Appellate Authority found that for in very same assessment year, assessee was subjected to assessment u/s. 143(3) r.w.s. 153A of the Act, wherein the Assessing Officer had added commission income on estimate basis applying the rate of 2% on ....