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ITAT Mumbai Deletes Section 69A Addition on Cash Handled by Payment Intermediary

TaxGuru
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Summary

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  • The ITAT Mumbai has deleted a ₹1,83,915 addition under Section 69A for Irfan Ahmad Shah, ruling that cash handled as an intermediary does not constitute taxable income.
  • The Tribunal recognized that the cash deposits were merely part of transactions with telecom and payment-service providers, with only the commission being taxable.
  • This decision also applies to AY 2018-19, where the Revenue's appeal for a ₹6.03 crore addition was dismissed.
  • The ruling emphasizes that intermediaries cannot be taxed on funds passing through their accounts without evidence of undisclosed income.

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