TaxTMI 
TaxTMI 
2025 (9) TMI 1881
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.... ORDER PER C.N. PRASAD, J.M. This appeal is filed by the Revenue against the order of the Ld. CIT(Appeals)-23, New Delhi dated 27.09.2023 for the AY 2012-13 in deleting the addition made in the assessment order. 2. Heard rival submissions, perused the orders of the authorities below. The Assessing Officer completed the assessment u/s 144/147 of the Act dated 18.12.2019 bringing to tax Rs....
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....mitted by the appellant in his statement and accordingly, commission income was calculated @2,000/- per crore while making assessment foray 2013-14 and AY 2016-17 to 2018-19. Details of addition made on account of commission in various AYs are as under: S.No. AY Date of order u/s 153A/143(3) Returned Income Addition on account of commission Assessed Income 1. 2013-14 13.....
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....er the rule of consistency, the AO ought to have maintained consistency in computing income from the transactions if the facts of the case are the same. 18. I have considered facts of the case as well as written submissions of the appellant. It is observed that income of the appellant has been assessed by accepting 'commission income @Rs.2,000/- per crore' as admitted by appellant in his ....
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....iew of the above discussion, the appeal of the appellant in respect of Ground No.7 is partly allowed." 4. As could be seen from the above, the Ld. CIT(A) restricted the commission income to Rs. 83,818/- as against Rs. 4,19,09,065/- observing that in the assessments made u/s 153A of the Act in the case of the assessee for assessment years 2013-14 to 2018-19 the commission income was assessed @ 2....