2026 (5) TMI 1211

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....Appeals) - NFAC, Delhi dated 19.03.2025 under section 250 of the Act arising from the assessment order dated 28.03.2023, passed by the Assessing Officer under Section 147 read with section 144B of the Income Tax Act, 1961 ('the Act') concerning Assessment Year 2018-19. 2. Since the underlying facts are common in the cross objections of the assessee and Revenue and pertain to same assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity. 3. The grounds raised by the Revenue are as under : i. "That the CIT(A) has erred in law and on the facts and circumstances of the case in reducing the addition made by the A0 to the 10% of Rs. 19,71,14,431/- i.e. Rs. 9,71,14,431/-. ....

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....ore us. The assessee has also filed a Cross Objection against the additions sustained challenging the proceedings u/s 148 and addition of 10% of the bogus transaction. 6. We find that the CIT(A) has decided the issue as under: "6. In this case, the AO received information regarding bogus sale and purchase undertaken by the appellant amounting to Rs. 19,71,14,431 through concerns promoted by accommodation entry operator Ashok Kumar Gupta. 6.1 In his statement recorded on 30.11.2018, during Survey u/s 133A, Shri Ashok Kumar Gupta S/o Late Sh. Hukam Chand Gupta, R/o C-602, SF Majlis Park, Adarsh Nagar, Delhi 110033 affirmed that he had provided accommodation entry through entities, Mahavir Prasad Suresh Kumar and Kalki Tra....