9911796707
TMI Blog2022 (12) TMI 1016X X X X Extracts X X X X X X X X Extracts X X X X ..... any business activity but the same are being carried out for the purpose of earning commission, we, therefore, fail to find any infirmity in the finding of the ld. CIT(A) confirming the addition made by the A.O based on facts and circumstances of this particular case. We, however, like to make it clear that our decision in confirming the finding of ld. CIT(A) of estimating commission income @0.5% of inflow and outflow of funds in the bank account should not be taken as a precedent in other similar cases as this is purely based on the facts of the instant case. Therefore, Ground Nos.3 4 raised on merits are dismissed. - I.T.A No. 42/Kol/2022 - - - Dated:- 21-12-2022 - Dr. Manish Borad , Accountant Member None appeared on behalf o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs.3,00,000 /- has been added to the total income of the appellant. 4. For that the addition made for an amount of Rs. 3,00,000/- is liable to be deleted. 5. For that appellant craves to leave, alter, modify or add any of the grounds of appeal at the time of hearing or before. 3. Brief facts of the case are that the assessee is a private limited company. Income of Rs.14,080/- was declared in the return filed on 07.12.12 for A.Y 2012-13. Based on credible information that a sum of Rs.6,00,00,000/- was received by the assessee from Sri Shyam Enterprise to its bank account held with Indian Bank and accordingly notice u/s 148 of the Act was issued on 28.03.2019. In compliance, the assessee filed the return on 04.04.2019 showin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent sources by the A.O about unexplained receipts in the bank account. We, therefore, dismiss Ground Nos.1 2 raised by the assessee holding that reopening of the assessment proceedings was valid and in accordance with law. Ground Nos.3 4 are regarding the addition towards undisclosed income of Rs.3,00,000/- computed by ld. A.O @0.5% of the bank credit entries of Rs.6,00,00,000/- carried out in the bank account held with the assessee during the year and the said addition being confirmed by the ld. CIT(A) has been challenged before us. Since, the ld. A.O has estimated the income based on his observation that the inflow and outflow in the bank account are not akin to any business activity but the same are being carried out for the pu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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