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2015 (9) TMI 1519

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..... me of Mr. S.K. Gupta without making any addition for unexplained cash credit. During the course of assessment Proceedings of the intermediary companies, including the Respondent Assessees, the AO sought directions from the Additional Commissioner of Income Tax under Section 144-A. The Additional CIT passed an order in which after discussing the facts he inter alia directed that it would be in the .....

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..... emption) in ITA No.683 of 2015 CM APP No. 18268 of 2015(exemption) in ITA No.684 of 2015 CM APP No. 18271 of 2015(exemption) in ITA No.685 of 2015 CM APP No. 18289 of 2015(exemption) in ITA No.686 of 2015 1. Allowed, subject to all just exceptions. 2. The applications stand disposed of. ITA No.683 of 2015 ITA No.684 of 2015 ITA No.685 of 2015 ITA No.686 of .....

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..... arrying on the business of providing accommodation entries on which commission/brokerage was received by him. 6. The ITAT referred to the order dated 28th December 2010 of the Settlement Commission which records inter alia that Mr. Gupta was an entry provider and that in his case only the amount of premium/commission received by him after reducing expenses incurred would be his additional incom .....

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..... ons in the hands of beneficiaries and Mr. S.K. Gupta without making any additions on this account in the hands of conduit entities . The said orders of the Settlement Commission or of the Additional CIT were binding on the AO. 8. It is not in dispute that the Respondent Assessees are the conduit entities and not the beneficiaries. Consequently, the order of the ITAT deleting the addition under .....

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