9911796707
TMI Blog2024 (11) TMI 153X X X X Extracts X X X X X X X X Extracts X X X X ..... addition to rectify the mistake apparent from the record in the assessment order passed u/s.153A r.w.s. 144 which has erroneously not made the addition on the actual sales and purchase figures while computing the commission income. CIT(A) further has directed the ld. A.O. to rectify the mistake apparent from the record in the assessment order passed u/s. 153A r.w.s. 144 of the Act in the case of the assessee dated 26.02.2021 and to determine the commission income according to the actual amount of bogus sales and purchases. We find no infirmity in the order of the ld. CIT(A) in deleting the addition made u/s. 69C of the Act and in directing the ld. A.O. to rectify the mistake apparent from record in the assessment order passed u/s. 153A r.w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .132 of the Act carried out at the business premises of One World Industries Pvt. Ltd. and others dated 06.11.2019, the ld. Assessing Officer (ld. A.O. for short) issued notice dated 23.06.2021 u/s.153C of the Act for A.Ys. 2014-15 to 2019-20 and u/s. 143(2) of the Act for A.Y. 2020 to 2021. The assessee filed its return of income in response to notice u/s. 153C of the Act. The assessee s case was transferred to ld. A.O., CC-8(2) who then issued notice u/s. 142(1) of the Act dated 10.11.2021, requiring the assessee to file details pertaining to the sales and purchases entered into by the assessee with various group companies of One World Industries Pvt. Ltd. which are alleged to be accommodation entry providers. It is also observed that a s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nducted in One World Industries Pvt. Ltd has already been considered while framing the assessment u/s.153A of the Act and that the impugned addition made by the ld. A.O. was without any new incriminating material found or seized during the search of One World group entities. 6. The Revenue is in appeal before us, challenging the impugned order of the ld. CIT(A). 7. We have heard the rival submissions and perused the materials available on record. It is observed that the Revenue has challenged the deletion of addition by the ld. CIT(A) which was made by the ld. A.O. It is evident that the ld. A.O. has made the impugned addition to the extent of the difference amount of bogus purchases and sales entered into by the assessee which was inadvert ..... X X X X Extracts X X X X X X X X Extracts X X X X
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