BHERA RAM BAGRIA,NEW DELHI vs. ITO WARD 44(1) , DELHI
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the interest income was not an accommodation entry and that the Revenue's action was without merit. The addition made by the lower authorities was deleted.
What were the facts?
The assessee reported interest income of Rs. 78,527/- from M/s Kutch Chemical Industries P. Ltd. The lower authorities treated this interest as an accommodation entry and made an addition for commission. The assessee had consistently offered similar interest income as income from other sources in prior years.
What were the issues?
Whether the interest income received by the assessee was an accommodation entry or genuine income from other sources. Whether the addition made on account of commission was justified.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.1272/Del/2026 Assessment Year:2020-21 Bhera Ram Bagria, Vs. Income Tax Officer, RZ-111, B Kailash Puri Extn. Gali Ward 44(1), no. 8, Sagarpur, Nasirpur. Civic Centre, Delhi PAN: AKCPB3226F (Appellant) (Respondent) Assessee by Sh. Sushil Chadha, CA Department by Sh. Nirmal Nangia, Sr. DR Date of hearing 09.07.2026 Date of pronouncement 09.07.2026 ORDER This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, [in short, the “Ld. CIT(A)/NFAC”], Delhi’s order dated 10/12/2025 having DIN & Order No. ITBA/NFAC/S/250/2025-26/1083527997(1) involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Coming to the asssessee’s sole substantive ground raised herein, it transpires during the course of hearing, that he is aggrieved against both the learned lower authorities’ respective assessments and lower appellate findings treating the interest
ITA No.- 1272/Del/2026 Bhera Ram Bagria income of Rs. 78,527/- not as income from “other” sources but an accommodation entry followed by commission estimation thereupon amounting to Rs.2,356/- forming subject matter of addition u/s 69A of the Act.
That being the case, it is hardly any dispute that the assessee has all along been getting his interest income herein from M/s Kutch Chemical Industries P. Ltd., who had availed this corresponding loan from him way back in FY 2011-12. It is further emphasized that there has been no dispute all along with the similar nature of interest income having got assessed as income from “other” sources only. This tribunal, therefore, finds no merit in the Revenue’s action holding the assessee’s interest income as an accommodation entry(ies). Deleted accordingly.
This assessee’s appeal is allowed. Order pronounced in the open court on 09th July, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER
Dated: 20th July, 2026. Pooja. Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi
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