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TMI Blog2022 (2) TMI 574X X X X Extracts X X X X X X X X Extracts X X X X ..... per CIT(A) it is not a disputed fact. The shroff acts as a channel between two parties. It is apparent from the bank account in question that the cash were deposited and withdrawn from time to time. During the proceedings, the assessee recorded his statement and categorically explained the nature of transaction that he is getting a commission at ₹ 0.25 paise on transaction of Rs. one lakh. All deposits in the bank account cannot be treated as income of the assessee. During the assessment proceedings, the learned AO came to know that assessee is working as shroff which means commission agent. After going through the bank statement, it was revealed that cash deposited and withdrawals were made regularly during the year under consider ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 377; 5,88,43,806/- in his current A/c. No. 015305002632 with ICICI Bank Ltd., Rajkot. With a view to verify the quantum of cash deposits the AO called for bank statement from ICICI Bank Ltd. u/s. 133(6) on perusal of which it was noticed that the assessee has deposited huge amount of cash in aggregate of ₹ 5,88,43,806/- on various dates in his above bank account. During the course of assessment proceedings the assessee in his statement recorded on oath as well as in response to the show cause notice submitted that the cash deposits in aggregate of ₹ 5,88,43,806/- made in his A/c. No. 015305002632 belongs to the Ceramic Industries/Tiles Manufacturing Companies of Morbi who are the clients of Shaileshbhai Marvania. It was also sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee recorded his statement and categorically explained the nature of transaction that he is getting a commission at ₹ 0.25 paise on transaction of Rs. one lakh. In our considered opinion, in such a case, all deposits in the bank account cannot be treated as income of the assessee. During the assessment proceedings, the learned AO came to know that assessee is working as shroff which means commission agent. After going through the bank statement, it was revealed that cash deposited and withdrawals were made regularly during the year under consideration. We do not find any ambiguity in the order passed by the learned CIT(A) and he has rightly directed the learned AO to compute the commission income @ 0.25 paise per lakh deposi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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