Loading judgment…
Facts
The Revenue's appeal concerned assessment year 2017-18, arising from proceedings under section 147 of the Income-tax Act, 1961. The appeal challenged the CIT(A)/NFAC's deletion of an addition made by the Assessing Officer.
Held
The Tribunal noted the CIT(A)/NFAC's clear finding that no amount of Rs. 40 lakhs formed the subject matter of any transaction between the assessee and M/s. A.K. Trading Company. This factual finding went unrebutted by the Revenue.
Key Issues
Whether the CIT(A) was justified in deleting the addition of Rs. 40,00,000 made by the AO on the grounds of an alleged accommodation entry.
Sections Cited
147, 143(3)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
ORDER This Revenue’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1082789002(1), dated 19.11.2025, involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case files perused. 2. This Revenue’s appeal raises the following substantive ground:
“1. Whether the CIT(A) is right in law in deleting the said addition of Rs.40,00,000/-, which was made by the AO on account of established Accommodation Entry made by the assessee with Ms. Eshverya Jain Prop. M/s. A.K. Trading Co. during the year under consideration?”
Suffice to say, a perusal of the CIT(A)/NFAC’s lower appellate discussion from page 6 onwards indicates that he has made it clear that no such amount in issue of Rs.40 lakhs forms subject matter of any transaction; be it credit or debit, between the assessee and M/s. A.K. Trading Company in the relevant previous year. This clinching factual finding under challenge has gone been unrebutted from the Revenue side. Rejected accordingly.