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Facts
The Revenue's appeal for assessment year 2019-20 concerned proceedings under section 147/143(3), challenging the CIT(A)'s deletion of an addition of Rs.31,36,009/- made by the Assessing Officer under section 69A.
Held
The Tribunal found no merit in the Revenue's contention that the assessee was a shell entity routing accommodation entries. However, it also noted the assessee's failure to prove the genuineness of the transactions. Accordingly, the Tribunal directed the Assessing Officer to assess a profit element of 3% on the impugned accommodation entries.
Key Issues
Whether the deletion of the addition made under section 69A for alleged accommodation entries was correct, and if so, what profit element should be taxed.
Sections Cited
147, 143(3), 69A
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 09.02.2026 Date of pronouncement 09.02.2026 ORDER This Revenue’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals)-30 [in short, the “CIT(A)”], New Delhi’s DIN and order no. ITBA/APL/M/250/2025-26/1080708559(1), dated 15.09.2025, involving proceedings under section 147/143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
Delay of 2 days in filing the Revenue’s instant appeal is condoned in the larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji& Others (1987) 167 ITR 471 (SC).