2026 (7) TMI 207

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....sed the following grounds of appeal: "1. The learned AO has wrongly passed the order under Section 144B of the Income tax Act, 1961 without giving sufficient opportunity of being heard to the appellant. 2. The learned CIT(A) has erred in confirming the addition of Rs 54,22,500 without considering the modality of travel business where agent is getting collection from passengers from whom agent gets cash and deposits it in the bank account for paying to the principal, agent. Normally agent accepts cheques from known and reliable passengers only. 3. The learned CIT(A) has wrongly confirmed the addition of 4% of Rs. 70,00,000 received from Arihant Trip Pvt. Ltd. as a loan and transferred it to Arihant Trip Solution (L....

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....addition of Rs. 1,57,318/- in respect of difference in commission shown in ITR and reflected in Form 26AS and treated the same as unexplained money u/s 69A r.w.s. 115BBE of the Act. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. The Ld. Authorised Representative (in short "Ld. AR") for the assessee submitted that both the authorities have passed the ex-parte order despite the details filed before the Ld. AO as well as before the Ld. CIT(A). The Ld. AR further submitted that the assessee has already offered to tax 1.89% commission related to the travel business where the agent is getting collection from passengers from whom agent gets cash and....