9911796707
TMI Blog2024 (10) TMI 1639X X X X Extracts X X X X X X X X Extracts X X X X ..... he appeals are connected, hence the same are being disposed off by this common order. We are taking appeal being ITA No. 2186/Del/2024 for AY 2013-14 as lead appeal and relevant grounds raised by the Revenue are as under : "1. That on the facts and in the circumstances of the case, the ld. CIT (A) has erred in deleting the addition of Rs. 4,62,77,975/- made on account of undisclosed sources u/s. 68 for unexplained entries in bank account ignoring the fact that assessee has failed to produce any concrete and any additional evidence in support of its contention. 2. The Ld. CIT (A) has erred in deleting the addition of Rs. 1,15,695/- made on account of unaccounted commission @ 0.25% ignoring the fact that this commission ch ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AR for the assessee submitted that the substantive addition made by the Assessing Officer in the hands of the assessee in the respective years are already offered to tax in the hands of Anand Kumar Jain and also relevant commission was disclosed by Anand Kumar Jain and offered to tax. He brought to our notice the decision of coordinate Bench in the case of Anand Kumar Jain in ITA No. 1318/Del/2019 & 2889/Del/2019 consolidated order dated 28.04.2023. He submitted that the commission income was also clearly offered to tax in the hands of Anand Kumar Jain and he supported the findings of ld. CIT (A). 5. Considered the rival submissions and material placed on record. We observed that the protective additions are made in the hands of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income cannot be subject to tax twice. Therefore, even on the issue of commission, we are not inclined to disturb the findings of the ld. CIT (A). Accordingly, this ground of appeal is also dismissed. 7. In the result, the appeal being ITA No. 2186/Del/2024 filed by the Revenue is dismissed. 8. With regard to appeals for AYs 2014-15 & 2015-16, since the facts are exactly similar to AY 2013-14 our above findings in AY 2013-14 are applicable mutatis mutandis in AYs 2014-15 & 2015-16. Accordingly, the appeals being ITA Nos. 2187 & 2188/Del/2024 for AYs 2014-15 & 2015-16 filed by the Revenue are dismissed. 9. To sum up : all the three appeals filed by the Revenue are dismissed. Order pronounced in the open court on this 16th day ..... X X X X Extracts X X X X X X X X Extracts X X X X
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