What did the Tribunal hold?

The Tribunal directed the Assessing Officer to assess the commission income component at 0.4%, referencing a similar assessment in the succeeding assessment year. The addition was to be recomputed accordingly.

The assessee appealed against an addition of Rs. 8,30,46,470/- made on account of alleged commission income at 2% on accommodation entries. The assessee confined its challenge to the rate of commission applied.

What were the issues?

The primary issue was the rate at which commission income on accommodation entries should be taxed. The Tribunal considered the rate applied in a subsequent assessment year.

Sungold Trade Private Limited vs ITO | ITAT Delhi 2026

Income Tax Appellate Tribunal, DELHI BENCH ‘A’, NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

Hearing: 11.08.2026Pronounced: 17.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI

BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 6547/Del/2025; Assessment Year: 2017-18 Sungold Trade Private Limited Vs Income Tax Officer, 107, Shivlok House-1, Karampura Ward- 24(3), Commercial Complex, New Delhi- 15 C R Building, Delhi- 02 (APPELLANT) (RESPONDENT) PAN No. AANCS4646J Assessee by: Sh. Gurjeet Singh, CA Revenue by : Sh. Balkishan Gopal, Sr. DR Date of Hearing: 11.08.2026 Date of Pronouncement: 17.08.2026

ORDER PER SATBEER SINGH GODARA, JM: This assessee’s appeal for assessment years 2017-18, arises against Commissioner of Income Tax (Appeals) [in short, the “CIT(A)”], Delhi-23’s order dated 22.08.2025, passed in DIN and order no. ITBA/APL/S/2025/2025-26/1079870666(1), involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case files perused.

Suffice to say, it transpires during the course of hearing at the outset that the assessee/appellant herein is aggrieved against both the learned lower authorities’ action applying the alleged commission income @ 2% on its alleged accommodation entries resulting in addition of Rs. 8,30,46,470/-; in assessment order dated 31.12.2019 as upheld in the lower appellate discussion.

That being the case, the assessee/appellant submits very fairly that it confines its challenge only to the extent of rate of the aforesaid commission component @ 2%. Mr. Singh further invites the tribunal’s attention to the Assessing Officer’s assessment order dated 21.03.2025 in the assessee’s case itself assessing the very nature of commission income @ 0.4% in the succeeding assessment year A.Y. 2018-19 which has gone unrebutted from the Revenue side. We thus deem it appropriate to direct the learned Assessing Officer to assess the assessee/appellant herein qua its commission income component in the alleged accommodation entries @0.4% in very terms followed by his consequential computation as per law.

No other ground or argument has been pressed before us.

This assessee’s appeal is partly allowed. Order pronounced in the open court on 17.08.2026 .

Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 17.08.2026 *Pooja Mittal, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR

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SUNGOLD TRADE PRIVATE LIMITED,DELHI vs. ITO, WARD 24(3), DELHI

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