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Facts
The assessee is in appeal against the CIT(A)'s order concerning assessment year 2010-11. The lower authorities disallowed/added an amount of Rs.1,21,025/- and an alleged commission element of Rs.2,420/-.
Held
The Tribunal found no merit in sustaining the disallowances/additions. It observed no clear-cut nexus between the assessee's transactions and the seized materials, and thus directed the deletion of the impugned disallowances/additions.
Key Issues
Whether the disallowances/additions made by the lower authorities are sustainable without a clear nexus between the assessee's transactions and the seized materials.
Sections Cited
143(3), 147
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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 28.05.2025 Date of pronouncement 28.05.2025 ORDER 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’).
Heard both the parties. Case file perused.
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