M/S. ADMIRAL FINSTOCK PVT. LTD.,,NEW DELHI vs. ITO, NEW DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI BEFORE SH. SATBEER SINGH GODARA, JUDICIAL MEMBER AND SH. NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 2724/Del/2016 (Assessment Year : 2011-12) Admiral Finstock Pvt. Ltd. Vs. ITO G-20, Dewan House, Ward – 1(2) Ajay Enclave New Delhi New Delhi – 110 018 PAN No. AABCA 9977 A (ASSESSEE) (RESPONDENT) Assessee by Shri Abhinav Singh, Adv. Revenue by Shri Vikram Singh Sharma, CIT-D.R. Date of hearing: 03.07.2026 Date of Pronouncement: 03.07.2026 ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER : This captioned appeal has been filed by the assessee against the order of the Learned CIT(A)-I, New Delhi dated 10.03.2016 arising out of the assessment order under section 143(3) of the Act on 28.02.2014 by the Income Tax Officer, Ward – 1(2), New Delhi for Assessment Year 2011-12. 2. Brief facts of the case are that assessee-company is a non- banking financial company not accepting public deposits. Return of income was filed on 31.03.2013 declaring nil income. Assessment was

ITA No. 2724/DEL/2016 [A.Y 2011-12] Admiral Finstock Pvt. Ltd. V. ito framed under section 143(3) of the Act on 28.02.2014 and determined the total income at Rs.1,28,88,480/- by adding current liabilities and unsecured loans of Rs.66,87,030/- and Rs.61,00,000/- respectively. The AO also added Rs. 1,00,000/- on account of legal fees paid without deducting TDS under section 40(a)(ia) of the Act. AO also added Rs.1,446/- as interest received on refund under section 244A of the Act, as surrendered by the assessee. 3. In the course of assessment proceedings, the AO conducted enquiry under section 133(6) of the Act from the creditors and lenders and either no reply was received or the notice was returned unserved. The assessee was issued show cause with regard to creditworthiness of the lenders and creditors and to explain such lack of verification of lenders/creditors. The assessee failed to discharge its onus of establishing identity, genuineness of transaction and creditworthiness of the lenders/creditors. Accordingly, the AO made the additions as above. Aggrieved, assessee was in appeal before the CIT(A). Learned CIT(A) upheld the order of the AO. 4. Aggrieved, assessee is before us with the following grounds: 1. “That on the facts and the circumstances of the case and in law, the assessee denies its liability to be assessed at an income of Rs.1,28,88,480/- as against the returned income of Rs. NIL and to pay additional tax demand of Rs. 64,23,420/-. 2. That on the facts and circumstances of the case the order passed by the CIT (Appeals)-I is bad in law and the addition be deleted.

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ITA No. 2724/DEL/2016 [A.Y 2011-12] Admiral Finstock Pvt. Ltd. V. ito 3. That the CIT (Appeals)- I has erred in law as on facts in upholding an addition of Rs. 1,27,87,030/-u/s 68 of the Income Tax Act on account of Unsecured Loan of Rs. 61,00,000/- and Current Liability of Rs.66,87,030/- by alleging that the Assessee company has failed to satisfy the provision of section 68 of Act. While doing so the CIT (Appeals)-1 has failed to appreciate that confirmations of all the parties were duly filled with supporting documents. 4. That on facts and circumstances of the case and in law, the learned AO has erred in initiating penalty proceedings under section 271(1)(c) of the Act. 5. That the Interest under Section 234B of the Act has reduced consequently.” 5. The ld AR before us could not present any evidence or materials for us to question the decision of the CIT(A). We find that in the course of the appellate proceedings, the assessee filed additional evidences/documents under Rule 46A of the Rules. The CIT(A) called for the Remand report and on the basis of remand report and additional evidences, arrived at the conclusion that the liabilities shown of Rs 66,87,030/- from seven parties were non-existent. Similarly, loans of Rs 61,00,000/- from three parties were again found to be non-genuine. In the remand proceedings also, the summons u/s 131 of the Act issued to these parties remained uncompiled with. The assessee also failed to produce any parties for verification during the remand proceedings. The findings of the CIT(A) that the loans were accommodation entries and there was no creditworthiness of the lenders, was not rebutted. In such facts and circumstances of the instant case, we find no reasons to interfere with the decision of the CIT(A). The ground is dismissed. Page 3 of 5

ITA No. 2724/DEL/2016 [A.Y 2011-12] Admiral Finstock Pvt. Ltd. V. ito 6. In the result, the appeal of the assessee in ITA No. 2724/DEL/2016 is dismissed. Order pronounced in the open court on 03.07.2026

Sd/- Sd/- (SATBEER SINGH GODARA) (NAVEEN CHANDRA) JUDICIAL MEMBER ACCOUNTANT MEMBER Date:- 27.07.2026 Priti Yadav, Sr. Ps* Copy forwarded to: 1. Assessee 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI

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