2026 (5) TMI 1753

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....udgement / Order / Decisions)<br>Dated:- 23-4-2026<br>ITA No. 271/Ran/2024, ITA No. 272/Ran/2024, ITA No. 273/Ran/2024, ITA No. 274/Ran/2024, ITA No. 275/Ran/2024, ITA No. 276/Ran/2024, ITA No. 380/Ran/2024 - -<br>Income Tax<br>SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER For the Department Represented : Shri Ashish Kumar Deharia, CIT-DR For the Assess....

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..../s Atibir Industries Company Ltd and unexplained expenditure thereof. It was the submission that there was a search and seizure operation on the said Atibir Group and M/s Atibir Industries Company Ltd. has offered the entire unsecured loans received from various companies as its income by making a disclosure of Rs. 25.00 cores. It was the submission that as the entire unsecured loans which have be....

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.... ultimate beneficiary of the bogus unsecured loans. This being so, the ld. CIT(A) has deleted the addition in the hands of the assessee. The revenue has not been able to dislodge this finding of fact as arrived at by the ld. CIT(A). As M/s Atibir Industries Company Ltd. has already disclosed the entire unsecured loans received, the addition is no more called in the hands of the assessee and the or....

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.... by the M/s Atibir Industries Company Ltd. as its income, obviously under these circumstances, the commission income could not have been added in the hands of the assessee. However, the ld. CIT(A) has restricted the commission @ 1%. The assessee has also not challenged this restriction of commission of 1%. The revenue has not been able to produce any concrete substance that 1% commission as restri....