2026 (8) TMI 952

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....nt : Sh Balkrishan Gopal, SR DR ORDER PER SHRI ANUBHAV SHARMA, JUDICIAL MEMBER: These appeals preferred by the Assessee against the order of the Ld. National Faceless Appeal Centre, (NFAC), Delhi (hereinafter referred to as the First Appellate Authority or 'the ld. FAA' for short) in appeals filed before him against the orders of the ld. Assessing Officer (hereinafter referred to as the L....

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.... 8 which was primarily argued and contested before us and for convenience the ground No. 8 for AY: 2018-19 is reproduced below: 8. That the Ld. CIT(A) erred in ignoring the consistent stand of the Appellant that he is a kachhaaadti/commission agent in food-grains, maintaining regular books, stock records and audited accounts, and that only a small commission margin of about 0.5% was earne....

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....es amount cannot be treated as unexplained income. In this context, ld. DR has however, relied the impugned orders. 4. We have considered the rival contentions and perused the material on record. Now, with regard to the contention of ld. AR we find substance that the return of income, balance sheet, trading account and Form 3CB, stock registers, sales bills and ledger account reflecting all qua....

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....blish genuineness of transaction by providing third party evidences such as transportation document weighment slips or confirmation from the alleged suppliers. However, with regard to the evidences of assessee no conclusion were drawn to show that the evidences of assessee were not considerable. 5. In the aforesaid circumstance we are of the considered view that when assessee pleads that if at ....