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TMI Blog2013 (2) TMI 296X X X X Extracts X X X X X X X X Extracts X X X X ..... ubstantial question of law arises for consideration. On account of the finding recorded by the Tribunal, the amount disclosed by the assessees as their income has been assessed to tax as income in terms of Section 44-AD . If in the proceedings against PACL India Limited, a finding is recorded that the transactions were not genuine, then the same would be liable to be added back to the income of PA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mentioned 17 appeals arising out of order dated 31.03.2010 passed by the Income Tax Appellate Tribunal, Delhi Bench 'D' New Delhi (for short 'the Tribunal') in respect of the assessment year 2006-07. The Revenue has claimed the following substantial questions of law: 1. Whether the Ld. ITAT has erred in deleting additions made in the hands of the assessee on the protective b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... found that the assessees have not done any contract work of PACL India Limited. Since no work has been done by the assessees, therefore, no expense can be allowed. Thus, the receipts of the assessees from PACL India Limited were treated as income of the assessees under the head 'Income from business or profession' on protective basis. Such order passed by the Assessing Officer was challen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come of the assessees but only the profit from such receipts can be brought to tax. The assessees herein being found to be name lenders could have charged only the commission for lending the name. Therefore, the income of the present assessees are only to the extent of receiving commission. Since all these persons have offered 8% of their income, no further amount is taxable. Learned counsel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment passed by the Tribunal would require no interference so far as the assessees in the present appeal are concerned. The finalization of the assessment proceedings against the assessees has, thus, no effect in respect of the assessment of PACL India Ltd. In view of the above, we do not find that any substantial question of law arises for consideration by this Court in the present appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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