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2024 (10) TMI 1617

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..... UDICIAL MEMBER: 1. This appeal by assessee is directed against the order of National Faceless Appeal Centre, Delhi [for short to as "NFAC/Ld. CIT(A)"] dated 08.03.2024 for assessment year 2013-14, which in turn arises out of assessment order passed by the Assessing Officer under section 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') dated 26.05.2023. 2. Rival .....

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..... eturn of income. The commission earned by assessee varies from 0.15% to 0.20% per Rs. 100/-, which is depending upon clearance and profile of persons. The Ld.CIT(A) confirmed the action of Assessing Officer. The Ld. AR for the assessee further submits that Assessing Officer also made addition of Rs. 1.20 lakh under section 69 of the Act on the ground that assessee has given such amount to M/s Hari .....

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..... d-Trib.)/[2016] 51 ITR(T) 250 (Ahmedabad - Trib.) also confirmed the addition to the extent of 0.10%. Further, Ld. AR for the assessee relied in the case of Shri Rohit Pravindhandra Panwala vs. ACIT in IT(SS)A No.608-612/Ahd/2010 dated 31.05.2011 wherein the co-ordinate Benches sustained the addition to the extent @ 0.125% i.e., twelve paisa per rupees hundred. On the addition of Rs. 1.20 lakh und .....

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..... venue has assessed commission income @ nine paisa or ten paisa per rupees hundred. However, in case of assessee, the Revenue has followed similar income assessed @ 1.00 % per hundred rupees. The Ld. AR for the assessee relied on the decision of Sanjay R Shah (supra) and in the case of Rohit P Panwala (supra) wherein similar income was assessed @ ten paisa or twelve paisa per rupees hundred. Thus, .....

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