IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER (Assessment Year: 2010-11)

Blueray Trading Pvt. Ltd., The Dy. Commissioner of Vs.

306, Snehadisha, Parawadi, Income-tax, Highway Road, Thane-400601 Central Circle-1(1), Ahmedabad [PAN : AAFCM 8859 D]

(Appellant) .. (Respondent Appellant by : Shri Mehul K. Patel, Advocate Respondent by: Shri Abhijit, Sr. DR Date of Hearing 16.09.2025 Date of Pronouncement 25.09.2025

O R D E R

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-

Delay Condoned.

This appeal has been filed by the Assessee against the order dated

30.08.2023 passed by the Ld. Commissioner of Income-Tax (Appeals)-11, Ahmedabad (‘Ld. CIT(A)’ in short), under Section 250 of the Income-tax Act, 1961 (‘the Act’ in short), relating to the Assessment Year 2010-11.

2. The assessee has raised following grounds:-

“1. The Ld. AO erred in law and on facts in making addition of Rs. 33,50,000/- treating the same as commission expenses paid by the Appellant for availing the alleged accommodation entries to the tune of Rs.6.70 crores.

2. The Ld. AO erred in law and on facts in not appreciating that the subject matter of pa