Commission-Based Business Proven: Tribunal Rejects Section 44AD and Upholds 5% Profit Rate

ITO Vs Mahamad Khayyum Mahamad Hanif Shaikh (ITAT Pune)

Commission Agent, Not Trader -100% Cash Deposit Addition Replaced with Reasonable 5% Profit— ITAT Rejects 44AD -Revenue’s Appeal Fails

Assessee, engaged in the scrap trading/commission business, did not file ROI. Based on cash deposits of ₹99,73,439 in his account with Shri Renuka Mata Multi-State Urban Co-operative Society, AO reopened the case u/s 147. As assessee did not respond to statutory notices, AO treated the entire deposits as unexplained money u/s 69A, taxing 100% of the amount.

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