Bhavesh Commotrade P. Ltd. v Dy. CIT (2024) 110 ITR 180 (Ranchi)(Trib); ACIT v. Suresh Kumar Agarwal (2024) 110 ITR 180 (Ranchi)(Trib)

S. 68 : Cash credits-Accommodation entries-Share capital, share premium and unsecured loan-Earning commission income a 20 Paise Per Rs. 100-Credit and debit entries in the bank account-Addition is deleted.

Held that the money received by the assessee was immediately passed on to other intermediaries or final beneficiaries so that the assessee could only be taxed in respect of the commission received by it for providing the accommodation entries. Accordingly, the order of the Commissioner (Appeals) was incorrect and, therefore, to be set aside with the direction to the Assessing Officer to delete the addition and assess the commission income at 20 paise per Rs. 100. Relied on  ITO v. Angel Cement P. Ltd(2021) 88 ITR 616(Delhi)(Trib)   Prem Castings P. Ltd. v. CIT (A)(2018) 11 ITR-OL 216 / [2017 88 taxmann.com 189 (All)(HC).(AY. 2011-12 to 2014-15)

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