9911796707
TMI Blog2025 (5) TMI 619X X X X Extracts X X X X X X X X Extracts X X X X ..... and engaged in the business of direct selling agent of M/s. Finbud Financial Services Pvt. Ltd. In this case information was received from NMS module of Insight portal that the assessee has received commission or brokerage of Rs. 71,97,994/- and has not filed his return of income. Therefore, the case of the assessee was reopened with the prior approval of Addl. CIT, Range-1, Nashik. Notice u/s 148 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') dt 30.03.2021 was issued and duly served on the assessee. However, neither the assessee filed any return in response to the notice u/s 148 of the Act nor responded to the notices issued by the Assessing Officer u/s 142(1) of the Act. The Assessing Officer, therefore, completed the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the receipts of Rs. 71,97,994/- as unexplained income and completed the assessment on total assessed income of Rs. 71,98,000/-vide order dated 25.03.2022. 5.1 The appellant filed the present appeal against the order of AO and the submissions filed in this regard during the present appeal proceedings have been reproduced in the preceding paragraphs. However, the appellant did not file any fresh documentary evidences in respect of the expenditure incurred except for requesting to estimate his income. No documentary evidence supporting the nature of income has been produced by the appellant except for the form 26AS which is already on record. The appellant stated that he is a direct selling agent at M/s. FINBUD financial services Pvt. Ltd, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an and allied services to such customers and she had incurred substantial expenditure for providing such services and therefore, only the net income reasonably estimated on gross receipts derived by her ought to have been taxed on facts of the case and in law. 3] The appellant submits that the asst. proceedings were conducted during Covid period and since the appellant lady was a senior citizen aged around 70 years susceptible to health issues, she could not make proper compliance before the A.O. which resulted into ex-parte asst. u/s 144 and therefore, the matter may please be set aside to the file of the A.O. to conduct the asst. afresh after providing one more opportunity of being heard, in the interest of justice. 4] Without prejudi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /- which is the gross commission received by the assessee. We find the Ld. CIT(A) / NFAC upheld the action of the Assessing Officer, the reasons of which have already been reproduced in the preceding paragraphs. It is the submission of the Ld. Counsel for the assessee that bringing to tax the entire gross receipts without granting any proportionate expenditure will cause grave injustice to the assessee. A perusal of the order of the Ld. CIT(A) / NFAC would show that the Ld. CIT(A) / NFAC has basically dismissed the appeal of the assessee on the ground that the assessee did not file any fresh documentary evidence in respect of expenditure incurred nor filed any details for the activities of the assessee in the previous and subsequent years. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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