Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2024 (3) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2024 (3) TMI 251 - ITAT DELHIAddition of contract receipts - Estimation of Profit / Income - bogus activity as assessee despite repeated opportunity could not justify the transactions - as noticed that apparently the said concern was paying commission of about 1% to unidentified brokers for arranging such transactions - assessee denied the allegation of receiving a contract - AO received the information that the contract price was Rs. 16,93,71,626/-, but he accepted the contract receipts of Rs. 29,65,16,795/- and estimated profit at 8% and made addition - CIT(A) deleted the addition HELD THAT:- We fail to understand what was the contract receipts was it 29.65 crores or 16.93 crores? Further, when the MD of Totem Infrastructure Ltd. has stated that the commission ranges from 0.25% to 1%, then we fail to understand what is the basis for estimating the profit at 8%. In our considered view, the entire addition has been made on surmise and conjecture without there being any demonstrative evidence; therefore, the findings of the CIT(A) cannot be faulted with. Appeal of the Revenue is dismissed.
|