2026 (7) TMI 492

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.... for the Assessment Year (AY) 2018-19. 2. At the time of hearing, the Ground Nos.2 & 3 are not pressed and therefore, the same are dismissed as not pressed. Similarly, the Ground No.1 is general in nature and does not require any specific adjudication. 3. The issue in Ground No.4 is against the confirmation of addition of Rs. 86,98,551/- by the Ld. CIT(A) as made by the Assessing Officer (in short, 'AO') on account of deposits/credit entries in State Bank of India (SBI) by treating the same as income of the assessee. 4. The facts in brief are that the assessee Smt. Sweety Agarwal was the proprietor of M/s Ekta Telecom at the relevant point of time and the said firm was the commission agent of Idea Mobile Commerce Service Ltd and Ad....

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..... 8,370/-. The statutory notices u/s 142(1) and 143(2) of the Act along with the questionnaire, calling upon various details and evidences were issued and served upon the assessee. The assessee partly replied the notices issued by the AO. The assessee submitted reply dated 12.10.2022 that Sweety Agarwal, the proprietor of M/s Ekta Telecom, engaged in the business in facilitating direct money transfer services via mobile applications. These services were offered through platforms managed by Aditya Biala Idea Payment Bank Ltd. and Idea Mobile Commerce Services Ltd. The assessee used to accept cash on behalf of these companies from the customers in the remote areas and used to deposit in the said bank account. Therefore, the money remitted to ....

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....ies on the money transferred amounting to Rs. 1,69,85,250/- which rightly reflected in 26AS on the Income-tax Appeal. However, the addition was made by the AO and confirmed by the Ld. CIT(A), on the ground that the assessee had failed to provide agreements with these companies. We have examined the form 26AS as well as the bank statement of M/s Ekta Telecom with SBI and find that the assessee was collecting the money from the customers and used to transfer the same to these two companies, through RTGS/NEFT to the account of these companies in lieu of commission. 7. We note that from the pattern of entries of the bank account that the highest balance on any single day was only Rs. 2,15,649/- and there were regular remittances after every ....