GOPAL SIVAKUMAR,TRICHY vs. ACIT, CIRCLE-1, TRICHY

The assessee is an individual and is engaged in the business providing leads of eligible loan applicants to one Mr. T. Shaktivel who is the authorized agent of HDFC Bank. The assessee receives commission on fixed percentage. The assessee filed the return of income for AY 2023-24 on 25.11.2023 declaring total income of Rs.4,86,620/-. The case was selected for scrutiny, and the statutory notices were duly served on the assessee. The AO called on the assessee to furnish various details towards credit card purchases and commission payments etc. Since the assessee could not provide the details called for fully, the A.O completed the assessment assessing the income at Rs.26,11,417/-. Aggrieved, the assessee filed further appeal before the CIT(A). Even before the CIT(A), the assessee did not furnish proper details substantiating the source and the genuineness of the impugned additions and therefore the CIT(A) confirmed the additions made by the A.O. The assessee is in appeal before the Tribunal against the order of the CIT(A).

We have heard the parties and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee submitted that the assessee could not file the documentary evidence called for by the lower authorities due to lack of proper advice and support from the tax consultant. The Ld. AR filed a petition under Rule 29 of ITAT Rules for admissions of additional evidence in the form of affidavits from various parties, bank statements, PAN and Aadhar details of parties, etc. since the additional evidence now submitted goes to the route of the impugned additions made by the lower authorities in the interest of justice, we admit the same for substantial justice. Considering that the contentions of the assessee regarding source for credit card payments and other impugned additions need to be verified factually based on the evidences now submitted by the assessee, we

In the result, the appeal of the assessee is allowed for statistical purposes.