Entire sales amount cannot be taxed in the hands of assessee who acted as conduit for commission

Saket M. Jain (HUF) Vs PCIT (ITAT Ahmedabad) In the assessment framed in the case of M/s Greenwell Orchard under section 143(3) read with section 147 of the Act has been set aside by the learned Pr. CIT under section 263 on the reasoning that the entire amount of sale proceeds is unaccounted income of the assessee. From all these above details, it is revealed that it was the Greenwell Orchard which was engaged in generating/converting its unaccounted income into agriculture income wherein the assessee was only one of the conduit. Thus, in our considered view the entire amount of sales cannot b...