SHREE YUGAL JODI SECURITIES PVT. LTD,NEW DELHI vs. ACIT-CIRCLE-23(1), NEW DELHI

This assessee’s appeal for assessment year 2010-11, arises against the Commissioner of Income Tax (Appeals)-XXV [in short, the “CIT(A)”], New Delhi’s order dated 25.02.2019 passed in case no. 10087/18-19, involving proceedings under section 143(3)/147
of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
2. Heard both the parties. Case file perused.
3. It is noticed at the outset during the course of hearing that both the learned lower authorities have disallowed/added an amount of Rs.1,21,025/- and the alleged commission element
Assessee by Sh. Rajiv Kumar, CA
Department by Sh. Manoj Kumar, Sr. DR
Date of hearing
28.05.2025
Date of pronouncement
28.05.2025
2 | P a g e thereupon @ 2% coming to Rs.2,420/-, respectively, in the course of assessment framed on 28.12.2017 and upheld in the lower appellate discussion.
4. I have given my thoughtful consideration to both the parties’
respective rival submissions against and in support of the impugned disallowances/additions. I find no merit to sustain the same. This is for the precise reason that apart from referring to some alleged client code modification “CCM”, there no clear-cut nexus between the assessee’s transactions vis-à-vis the corresponding seized materials, either indicated in the assessment findings or in the lower appellate discussion. That being the case, the impugned disallowances/additions have no legs to stand. The same are directed to be deleted.
5. This assessee’s appeal is allowed.
Order pronounced in the open court on 28th May, 2025 (SATBEER SINGH GODARA)

JUDICIAL MEMBER

Dated: 28th May, 2025. RK/-