Facts
The assessee, a ticket booking agent, deposited Rs. 118.25 Lacs in their bank accounts but failed to file supporting documents. The Assessing Officer (AO) estimated income at 10% and made an addition of Rs. 11.82 Lacs, which was confirmed by the CIT(A).
Held
The Tribunal acknowledged that a ticketing agent's margins are typically low. Considering past returns, the Tribunal directed the AO to estimate the income at 2% of the deposit, which would be in addition to the returned income.
Key Issues
Dispute regarding the estimation of income by the AO and confirmed by CIT(A) for a ticket booking agent.
Sections Cited
144
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “D” BENCH, CHENNAI
Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI MANU KUMAR GIRI, JM
(िनधा)रणवष) / Assessment Year: 2016-17) Shri Ananthanarayanan Rajasekaran ITO बनाम/ #70, Golden Avenue, NJV Nagar, Ward-2, Vs. Indira Nagar, Neyveli-607 801. Cuddalore. �थायीलेखासं./जीआइआरसं./PAN/GIR No.AAGPR-8687-Q (अपीलाथ�/Appellant) : (� थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Shri N. Arjun Raj (Advocate)– Ld.AR � थ�कीओरसे/Respondent by : Ms. Kavitha (Addl.CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 21-11-2024 घोषणाकीतारीख /Date of Pronouncement : 03-12-2024 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member)
Aforesaid appeal by assessee for Assessment Year (AY) 2016-17 arises out of the order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 22-08-2024 in the matter of an assessment framed by Ld. Assessing Officer [AO] on best judgment basis u/s. 144 of the Act on 19- 12-2018.
Upon perusal of assessment order, it could be seen that the assessee is engaged as ticket booking agent. The assessee deposited cash of Rs.118.25 Lacs in his bank accounts during the year but failed to file the supporting documents. Consequently, Ld. AO estimated income at 10% and made addition of Rs.11.82 Lacs. The Ld. CIT(A) confirmed the same against which the assessee is further appeal before us.
The Ld. AR placed on record profitability chart from AYs 2013-14 to 2024-25 and pleaded for a reasonable estimation. The Ld. AR submitted that the commission is received in lump sum on per ticket basis and the margins are very low. The Ld. Sr. DR opposed any interference in the estimation of income.
We concur that the assessee being a ticketing agent would receive commission on per ticket basis and therefore, its margins would be low. Considering the return of income for AYs 2013-14 to 2024-25, we direct Ld. AO to estimate the income at 2% of deposit of Rs.118.25 Lacs which would be over and above the returned income as admitted by the assessee. No other ground has been urged in the appeal.
The appeal stand partly allowed. Order pronounced on 3rd December, 2024.