ITAT Mumbai: AO Cannot Apply 50% Presumptive Rate U/s 44ADA to Business Income Declared U/s 44AD – Addition Deleted

Manoj Rajaram Sharma Vs ITO (ITAT Mumbai) ITAT Mumbai: AO Cannot Apply 50% Presumptive Rate U/s 44ADA to Business Income Declared U/s 44AD – Addition Deleted In this case, the assessee, a Business Correspondent (BC) of Fino Payments Bank, declared income u/s 44AD based on commission earned from customer transactions routed through a BC merchant account. The AO, despite accepting the turnover, arbitrarily applied a 50% profit rate (akin to u/s 44ADA) instead of the statutory rate under 44AD and made an addition. The ITAT held that the activity of a BC is a business activity and not a spec...