2026 (4) TMI 112

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....nd Shri Arvinder Pal Singh, CA For the Revenue : Shri Om Prakash, Sr. DR ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.4031/Del/2024 for AY 2017-18, arises out of the order of the ld National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'ld. CIT(A)', in short] dated 10.07.2024 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (h....

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....A noted that Assessee is the proprietor of two concerns, i.e., M/s Kuber Enterprises and M/s Image Promotion and Branding.The Learned CITA noted that Assessee had earned profit from one of the proprietorship concerns i.e., M/s Image Promotion and Branding, while he had incurred loss from another proprietorship concer M/s Kuber Enterprises. From the book results of M/s Kuber Enterprises, the Learne....

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....cash deposits in page 47 of his appellate order. He further noted that Assessee had made regular cash deposits in his bank accounts out of his cash sales and as such presumption regarding available cash being treated as undisclosed income is not in accordance with the records particularly in the absence of any finding or corroboration. Accordingly, the Learned CITA deleted the addition made in the....

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....n the case of Smile Microfinance Ltd vs ACIT reported in 479 ITR 172 (Mad) had categorically held that the enhanced rate of tax of 60% provided under section 115BBE of the Act shall not be applicable for transactions prior to 1.4.2017. Hence applying the tax at the normal rate of 30% plus applicable surcharge and cess, the tax effect involved in the present appeal of the revenue works out to Rs 57....