No Additions Without Specific Incriminating Material: ITAT Delhi

DCIT Vs SNW Smith Consultants Pvt. Ltd (ITAT Delhi) Delhi Tribunal dealt with Revenue’s appeals against relief granted by CIT(A) in commission income estimation for A.Ys. 2012-13, 2015-16 & 2016-17. Assessees were part of Adam Smith Group (ASG), engaged in discounting of bills & letters of credit. A search u/s 132 was conducted on 28.11.2017. Seized documents & LC Billing & Discounting (LCBD) software indicated that ASG was suppressing commission income, with gross commission estimated by AO at 1.28% of hundi amounts. AO made additions accordingly, alleging that substantial c...