TMI Blog2022 (2) TMI 765X X X X Extracts X X X X X X X X Extracts X X X X ..... mission bill was submitted by the HUF to the Accounts Manager of Ajnara India Ltd. Referring to TDS Certificate issued by Ajnara India Ltd. showing TDS on commission paid to HUF of the assessee and bank account of the HUF of the assessee with Oriental Bank of Commerce, wherein commission has been deposited after TDS. Considering all we are of the considered opinion that the commission incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as challenged the validity of the assessment order claiming that it is without jurisdiction, and (ii) Secondly, on merits, the assessee has challenged the addition of ₹ 8,35,000/- as alleged income of the assessee. 3. At the very outset, the ld. counsel for the assessee did not press the legal ground and the same is dismissed as not pressed. 4. Coming to the merits of the case, w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to our notice the decision of the ld. CIT(A) in the case of the brother of the assessee Shri Sanjiv Gupta and pointed out that on identical set of facts, similar commission income of ₹ 8.15 lakhs was assessed in the hands of HUF of Shri Sanjiv Gupta. 8. The ld. counsel for the assessee further drew out attention to the relevant documents to substantiate the earning of commission by the HU ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of commission to the HUF. Page 29 is the TDS Certificate issued by Ajnara India Ltd. showing TDS on commission paid to HUF of the assessee. Page 31 is copy of bank account of the HUF of the assessee with Oriental Bank of Commerce, wherein commission has been deposited after TDS. 12. Considering all these facts in totality, we are of the considered opinion that the commission income belonged to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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