2026 (9) TMI 321

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....r referred as "the Act"]. 2. The brief facts of the case are that the assessee did not file his return of income for A.Y. 2020-21. The AO had received an information that the assessee had made cash deposits of Rs. 32,61,949/- in his bank account and also received commission/brokerage of Rs. 33.50 lakhs on which TDS was deducted. The AO had, therefore, initiated proceeding u/s. 148A(b) of the Act on 29.01.2024 and a notice u/s. 148 of the Act was issued on 28.02.2024 after passing an order u/s. 148A(d) of the Act. In response to the said notice, the assessee had filed his return of income on 28.05.2024 showing income of Rs. 6,53,250/-. In the course of assessment, the AO had noticed that the total credits appearing in the bank account of ....

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....ts, the book rejection be treated as unlawful and returned income be accepted. 4. Your appellant prays to add/alter/delete the grounds of appeal. 5. Shri B T Thakkar, the Ld. AR of the assessee explained that the assessee was carrying on proprietary business in the name and style of Keshava Retails INC. During the year, the assessee was approached by M/s Narshidas Moraji Wadia to represent them before Gujarat State Disaster Management Corporation for undertaking certain projects. Accordingly, the assessee has received commission of Rs. 33.50 lakhs for procuring work order and execution of the project. The Ld. AR explained that the assessee had employed skilled worker for this purpose and had incurred expenses towards earning of ....

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....re commission of Rs. 33.50 lakhs as income of this year following the mercantile system of accounting. As against the total credit of Rs. 1,02,88,403/- in the bank account, the assessee has disclosed sales of Rs. 4,43,302/- only in his P&L account. No explanation was given regarding the balance credits as appearing in the bank accounts. The AO had, therefore, rightly rejected the books of accounts of the assessee and estimated profit @ 8% on the credits of Rs. 1,02,88,403/- as appearing in the bank account. As regarding commission of Rs. 33.50 lakhs received from M/s Narshidas Moraji Wadia, the assessee has neither furnished copy of the agreement nor explained the nature of services rendered by him for earning of this income. There was no j....