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“share application money”

Cash Credits & Unexplained ItemsSection 68Section 682,489 judgments

The decision most relied on for share application money is CIT v. Lovely Exports (P) Ltd. (216 CTR 195), cited in 854 judgments on BharatTax.

Leading authorities on share application money

CIT v. Lovely Exports (P) Ltd.
216 CTR 195 · 2008 · Supreme Court
854
citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Nemi Chand Kothari v. CIT
264 ITR 254 · 2003 · High Court
340
citing judgments

For a cash credit, merely transacting by cheque is insufficient to discharge the assessee's burden of proof. The assessee must prove the identity of the creditors, the genuineness of the transaction, and the creditworthiness of the creditors; upon which, the burden shifts to the revenue.

CIT v. Kamdhenu Steel & Alloys Ltd.
361 ITR 220 · 2014 · High Court
328
citing judgments

When making an addition under section 68, the creditworthiness or financial strength of an investor contributing share capital or share application money can be proved by producing their bank statements showing sufficient balance for the investment. The Supreme Court dismissed the SLP against this decision.

CIT v. Sophia Finance Ltd.
205 ITR 98 · 1994 · High Court
295
citing judgments

To discharge the burden of proof under Section 68 for share capital or share application money, an assessee must establish the identity of the shareholders and the genuineness of the transaction, confirming that the payment was truly made by them.

CIT v. Oasis Hospitalities P. Ltd.
333 ITR 119 · 2011 · High Court
292
citing judgments

When explaining cash credits under Section 68, the assessee must establish the identity of the creditor, their creditworthiness or financial capacity, and the genuineness of the transaction. Merely proving identity does not discharge this initial onus, which shifts to the Assessing Officer once these three elements are prima facie proven.

CIT v. Nipun Builders & Developers
350 ITR 407 · 2013 · High Court
264
citing judgments

For any sum credited in an assessee's books, including share application money, the assessee must prove the identity and creditworthiness of the creditor and the genuineness of the transaction. Failure to discharge this onus under Section 68 renders the amount taxable.

Judgments citing share application money

Onkar Parivahan Finance Private Limited, Kolkata Burrabazar vs. Dy. Commissioner of Income Tax, Circle 9(2), Kolkata, Chowringhee

In the result, the appeal of the assessee is allowed

ITA 793/KOL/2023[2015-2016]Status: DisposedITAT Kolkata21 Mar 2024AY 2015-2016

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2015-16 Onkar Parivahan Finance Private Dcit, Circle-9(2), Limited Kolkata Vs.

For Appellant: Shri Siddharth Agarwal, AdvocateFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. DR
Section 133(6)Section 143(2)Section 14ASection 68

compliances have been made from the end of assessee. He stated that when the assessee company discharged its onus in respect of the share application money received by it no addition can be made in the hands of assessee company. The ld. AR in order to substantiate its claim ... circumstances held as follows: “Both the Commissioner of Income Tax (Appeal) and the Tribunal below have in details considered the fact that the share application money was paid by account payee cheque, the creditor appeared before the Assessing Officer, disclosed its PAN number and also other details of the accounts

Onkar Parivahan Finance Private Limited, Kolkata Burrabazar vs. Dy. Commissioner of Income Tax, Circle 9(2), Kolkata, Kolkata Chowringhee Square

In the result, the appeal of the assessee is allowed

ITA 792/KOL/2023[2014-2015]Status: DisposedITAT Kolkata21 Mar 2024AY 2014-2015

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2014-15 Onkar Parivahan Finance Private Dcit, Circle-9(2), Limited Kolkata Vs.

For Appellant: Shri Siddharth Agarwal, AdvocateFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. DR
Section 131Section 143(2)Section 14ASection 68

compliances have been made from the end of assessee. He stated that when the assessee company discharged its onus in respect of the share application money received by it no addition can be made in the hands of assessee company. The ld. AR in order to substantiate its claim ... circumstances held as follows: “Both the Commissioner of Income Tax (Appeal) and the Tribunal below have in details considered the fact that the share application money was paid by account payee cheque, the creditor appeared before the Assessing Officer, disclosed its PAN number and also other details of the accounts

Deputy Commissioner of Income-Tax, Corporate Circle-1, Coimbatore vs. Ms Dar Paradise Pvt. Ltd., Coimbatore

In the result, appeal filed by the revenue is dismissed

ITA 1106/CHNY/2023[2017-18]Status: DisposedITAT Chennai21 Mar 2024AY 2017-18

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1106/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Dar Paradise Pvt. Ltd., Income Tax, V. 599, Raja Street, Corporate Circle -1, Coimbatore – 641 001. Coimbatore. [Pan: Aafcd-3066-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Clement Ramesh Kumar, Cit ""यथ" क" ओर से/Respondent By : Shri. N. Arjun Raj, Ca सुनवाई क" तारीख/Date Of Hearing : 05.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 21.03.2024

For Appellant: Shri. R. Clement Ramesh Kumar, CITFor Respondent: Shri. N. Arjun Raj, CA
Section 115JSection 131Section 133(6)Section 142(1)

आयकर अपीलीय अिधकरण, ‘सी’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी वी दुगा" राव, "याियक

Quality Apparel Exporters Pvt Ltd., Mumbai vs. Asst CIT Circle- 11(1)(1), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 487/MUM/2020[2000-01]Status: DisposedITAT Mumbai21 Mar 2024AY 2000-01

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Pranit TannaFor Respondent: Shri P.D. Chougule
Section 133ASection 144Section 148Section 250

erred in upholding the action of the Assessing Officer in making an addition of Rs 1,28,21,454, being share application money received by the appellants, on the basis of Survey Report of DDIT (Inv) Wing. The appellants contend that on the facts and in the circumstances ... allowed for statistical purposes. 14. The issue arising in ground no.4, raised in assessee‟s appeal, pertains to the addition on account of share application money received by the assessee. 15. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings

Quality Apparel Exporters Pvt Ltd., Mumbai vs. Asst CIT Circle- 11(1)(1), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 486/MUM/2020[1999-00]Status: DisposedITAT Mumbai21 Mar 2024AY 1999-00

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Pranit TannaFor Respondent: Shri P.D. Chougule
Section 133ASection 144Section 148Section 250

erred in upholding the action of the Assessing Officer in making an addition of Rs 1,28,21,454, being share application money received by the appellants, on the basis of Survey Report of DDIT (Inv) Wing. The appellants contend that on the facts and in the circumstances ... allowed for statistical purposes. 14. The issue arising in ground no.4, raised in assessee‟s appeal, pertains to the addition on account of share application money received by the assessee. 15. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings

The DCIT Circle-4(1)(1), Ahmedabad vs. West Side Cars Pvt. Ltd, Ahmedabad

In the result, the appeal filed by the revenue is hereby dismissed

ITA 1398/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad20 Mar 2024AY 2015-16

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकरअपीलसं./Ita No. 1398/Ahd/2019 धििाधरणवरध/Asstt. Year: 2015-2016 The D.C.I.T, West Side Cars Pvt.Ltd., Circle-4(1)(1), Vs. A/1-4, Solitaire Corporate Park, Ahmedabad. Nr. Divya Bhaskar, Makarba, S.G Highway, Ahmedabad.

For Appellant: Shri Tushar Hemani,Sr.AdvocateFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 68

company, is engaged in the business of car dealership. The AO during the assessment proceedings noticed that the assessee has shown receipt of share application money of Rs. 2,99,00,000/- through banking channel from its director detailed as under: 1. Shri Devendra Singh Bagga ... proceeding which were also verifiable from their respective ledger account, bank statement but the AO ignoring the fact explained, treated the amount of share application money credited in books as unexplained credit under section 68 of the Act to the extent of Rs. 2,59,00,000/- only. Further

DCIT 15(1)(2), Mumbai vs. Luxora Realtors Private Limited, Mumbai

ITA 2457/MUM/2023[2014-15]Status: DisposedITAT Mumbai20 Mar 2024AY 2014-15

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit 15(1)(2) V. M/S. Luxora Realtors Private Limited Unit No. 150, Avior Corporate Park Room No. 126-B, 1St Floor Nirmal Galaxy Lbs Road Aayakar Bhavan, M.K. Road Mulund (W), Mumbai- 400080 Mumbai- 400020 Pan: Aabco3197J (Appellant) (Respondent) Assessee Represented By : Shri. K.P. Dewani Department Represented By : Shri Ajay Chandra

Section 127Section 132(1)Section 143(2)Section 153CSection 68

Aanya Properties (I) Ltd., it was observed that assessment in the case assessee was completed for AY 2013-14 and the share application money received by the assessee was added to the total income of the assessee, the facts of the case for AY 2013-14 are discussed ... appropriated towards share capital allotment and balance Rs. 4,17,26,611/- was closing balance, kept as share application money pending allotment. In the assessment order for A.Y 2013-14, entire amount of gross receipts at Rs. 15,86,06,125/- was added u/s 68 of the Act, which included

Soubhik Exports Limited., Kolkata vs. DCIT, Cir-8(2), Kolkata / N E-Assessment Centre, Delhi.

ITA 1243/KOL/2023[2018-19]Status: DisposedITAT Kolkata19 Mar 2024AY 2018-19

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Ble

For Appellant: Shri P.K. Singh, A/RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(2)Section 143(3)Section 147Section 14ASection 250Section 68

assessee is a company (not being a company in which the public are substantially interested), and the sum so credited consists of share application money, share capital, share premium or any such amount by whatever name called, any explanation offered by such assessee-company shall be deemed

Soubhik Exports Limited., Kolkata vs. DCIT, Cir-8(2), Kolkata.

ITA 1242/KOL/2023[2012-13]Status: DisposedITAT Kolkata19 Mar 2024AY 2012-13

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Ble

For Appellant: Shri P.K. Singh, A/RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(2)Section 143(3)Section 147Section 14ASection 250Section 68

assessee is a company (not being a company in which the public are substantially interested), and the sum so credited consists of share application money, share capital, share premium or any such amount by whatever name called, any explanation offered by such assessee-company shall be deemed

M/S Landmark Exim Pvt Ltd., Kolkata vs. ITO, Ward-1(4), Kolkata

In the result, appeal of the assessee is allowed for statistical purposes

ITA 521/KOL/2020[2012-13]Status: DisposedITAT Kolkata19 Mar 2024AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Abhishek Bansal, ARFor Respondent: Shri Vineet Kumar, JCIT
Section 131Section 143(3)Section 250(6)Section 263Section 68

required details/ documents. 9. For that the under the facts and circumstances of the case the Ld. CIT(A) erred in considering the share application money of Rs. 3,29,50,000/ - as unexplained cash credit whereas all the information were duly on records. 10. For that

Ranisati Hosiery (P) Ltd., Kolkata vs. PCIT-4, Kolkata.

In the result, appeal of the assessee stands allowed

ITA 1278/KOL/2023[2012-13]Status: DisposedITAT Kolkata18 Mar 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.1278/Kol/2023 Assessment Year : 2012-13 Ranisati Hosiery (P) Ltd…….….…………............…...……………....Appellant Siddha Weston, Room No.126, 9, Weston Street, Kolkata – 700013. [Pan: Aafcr2959B] Vs. Pcit-4, Kolkata…………..….............................................…..…..... Respondent Appearances By: Shri Rajeeva Kumar & Giridhar Dhelia, Ar, Appeared On Behalf Of The Appellant. Shri Rakesh Kumar Das, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 31, 2024 Date Of Pronouncing The Order : March 18, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Revision Order Dated 12.03.2019 Of The Principal Commissioner Of Income Tax-4, Kolkata [Hereinafter Referred To As ‘Pcit’] Passed U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. As Per The Note Of The Registry, The Appeal Is Time Barred By 1722 Days. A Separate Application For Condonation Of Delay Has Been Filed Which Is Further Supported With The Affidavit Of Shri Bhupendra Bansal, Director Of The Assessee Company. It Has Been Explained That The Impugned Order Dated 12.03.2019. That The Copy Of The Order Was Not Served Upon The Assessee. That The Assessee Came To Know About The Passing Of The Impugned Order Only After The Receipt Of The Subsequent Assessment Order Passed U/S 144 R.W.S. 263 Of The Act. The Assessee

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 144Section 263

passed u/s 143(3) of the Act for de-novo assessment and directed the Assessing Officer to specifically examine the source of share application money, identity of investors, nature and genuineness of the transaction. The ld. PCIT further directed that to carry out the aforesaid investigation, the Assessing Officer will ... asked the assessee about the validity of the assessment order for want of necessary enquiries and verifications by the Assessing Officer relating to share application money and premium, to which the assessee had given a detailed reply. Once a point wise reply was given by the assessee, then a duty

Income Tax Officer, Ward-2(1), Hyderabad, Signature Towers, Kondapur vs. Green View Upvc Doors and Windows Private Limited, Hyderabad

In the result, appeal of the Revenue is treated as allowed for statistical purposes

ITA 373/HYD/2023[2016-17]Status: DisposedITAT Hyderabad15 Mar 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri K.C. Devdas, ARFor Respondent: Shri Waseem UR Rehman, DR
Section 1Section 41

Officer opined that the sundry creditors to the tune of Rs.1,12,39,396/- out of Rs.2,40,95,330/- was satisfactorily explained; share application money to the tune of Rs. 75,34,200/- was not found to be satisfactorily explained; whereas Rs. 3,69,381/- towards provisions ... aspects and jumped to the conclusion that all the new entries of the sundry creditors are satisfactorily explained. Same is the case with share application money. Learned CIT(A) did not discuss the merits of the case with reference to the findings of the learned Page 2 of 5 Assessing

Sharda Ferro Works(P)Ltd, Howrah vs. DCIT, Asansol

In the result, appeal of the assessee is allowed

ITA 954/KOL/2023[2012-13]Status: DisposedITAT Kolkata14 Mar 2024AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Sunil Surana, AdvocateFor Respondent: Shri P. P. Barman, Addl. CIT
Section 133(6)Section 143(3)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH KOLKATA BEFORE SHRI SONJOY SARMA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

New Infrastructure Private Limited, Borivali(West) vs. National Faceless Appeal Centre

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 3859/MUM/2023[2010-11]Status: DisposedITAT Mumbai13 Mar 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blenew Infrastructure Private Limited V. Acit- 13(1)(1) 23, B, Ganjawala Apartment 218, 2Nd Floor Svp Road, Borivali (W) Aayakar Bhavan Mumbai- 400092 Mumbai- 400020 Pan: Aaccn1678G (Appellant) (Respondent) Assessee Represented By : Shri Bhupendra Shah Shri Ashok Kumar Ambastha Department Represented By :

Section 143Section 148Section 234Section 271Section 68

circumstances of the case and in law, the Ld. AO erred in making the addition of Rs.50 lacs/-by way of share application money and the CIT[A] NFAC erred in confirming addition without any inquiry from the share applicant. 4. On the facts and circumstances of the case ... quash second reopening initiated u/s 148 3. To delete the addition of Rs 50 Lacs-wrongly made in respect of alleged unproved share application money 4. To delete interest u/s 234 & initiation of penalty u/s 271[1][c]. [D] General: The appellant reserve rights to add alter or delete

M/S. Korada Furniture Company Pvt Ltd., Hubli vs. Deputy Commissioner of Income-Tax, Circle-1(1) &Tps, Hubli

In the result, the appeal filed by the assessee is allowed

ITA 47/BANG/2024[2014-15]Status: DisposedITAT Bangalore11 Mar 2024AY 2014-15

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Sri.Siddesh Nagaraj Gaddi, CAFor Respondent: Sri.Sandeep Kumar H.S., Addl.CIT-DR
Section 143(2)Section 143(3)Section 250Section 271Section 271(1)(c)Section 274Section 68

notice u/s.143(2) of the Act on 18.09.2015. The reason for selection of the assessment for scrutiny was to examine the receipt of share application money by the assessee. The Assessing Officer completed the assessment u/s.143(3) of the Act vide order dated 19.12.2016 by making an addition of Rs.26

Bharath Hi-Tech Builders Pvt. Ltd., Bangalore vs. Dy. CIT, Circle-1(1)(2), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 1034/BANG/2023[2009-10]Status: DisposedITAT Bangalore11 Mar 2024AY 2009-10

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Sri.Inder Paul Bansal & Sri.Vivek BansalFor Respondent: Sri.Nilanjan Dey, Addl.CIT-DR
Section 147Section 148Section 151Section 153ASection 250

assessee was not under legal obligation' to prove the source of source in a case where shares have been allotted in respect of share application money in the relevant financial year itself. 8. That under the facts and circumstances of the case, Ld. NFAC has failed to appreciate that ... perused. In Ankit Agrochem (P.) Ltd. Vs JCIT, 89 taxmann.com 45 it was held that where DIT informed that assessee-company had received share application money from several entities which were only engaged in business of providing bogus accommodation entries to beneficiary concerns, reassessment on basis of said information

Balaji Infrastructure & Development Co., Mumbai vs. ITO 2(1)(1), Mumbai

In the result, ground no. 2 raised by the assessee is dismissed in above terms

ITA 1616/MUM/2020[2013-14]Status: DisposedITAT Mumbai11 Mar 2024AY 2013-14

Bench: Shri Aby T Varkey & Shri Gagan Goyalbalaji Infrastructure & Development Company Limited, 6Th Floor, New Excelsior Building, A. K. Nayak Marg, Fort, Mumbai-400 001 Pan: Aaacb8155C ...... Appellant Vs. Ito-2(1) (1), R. No. 561, 5Th Floor, Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ..... Respondent

For Appellant: Shri Sujay Waikul, Ld. ARFor Respondent: Shri S. Srinivas, Ld. DR
Section 143(2)Section 234BSection 24Section 250Section 271(1)Section 32(1)Section 57

seen that the own capital of the Appellant in forms of share capital is only Rs. 3,45,00,000/-. Further, there is share application money amounting to Rs. 2, 95, 00,000/- while the reserves and surplus as on 31.03.2013 is showing a negative balance of Rs. 6.61 Crores

Jet Lite (India) Ltd., Mumbai vs. DCIT, Central Circle-6 (Now CC-1), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 839/DEL/2019[1996-97]Status: DisposedITAT Delhi11 Mar 2024AY 1996-97

Bench: Shri M. Balaganesh & Shri Anubhav Sharmajet Lite (India) Ltd, Vs. Dcit, 13, Community Central Circle-6, Centre, Yusuf Sarai, (Now Cc-1), New Delhi New Delhi (Appellant) (Respondent) Pan:Aadcs4480L

For Appellant: NoneFor Respondent: Mr. Waseem Arshad, CIT DR
Section 156Section 250Section 251(1)(a)Section 251(1)(b)Section 271(1)(c)Section 275

cannot be treated at par with tax evasion which is coupled by active action of routing his our money in form of purported share application money. On the top of it, the appellant is not cooperating with the law by not furnishing the necessary details. It is a trite that

Sansar Trading (P) Ltd., Kolkata vs. ITO, Ward-5(2), Kol, Kolkata

In the result, appeal of the assessee is allowed for statistical purposes

ITA 544/KOL/2023[2012-13]Status: HeardITAT Kolkata08 Mar 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri A. N. Kesari, FCAFor Respondent: Shri Bonnine Debarma, JCIT
Section 131Section 142(1)Section 143(3)Section 14ASection 56(2)(viib)Section 68

income of Rs.5,767/-. In the course of assessment, Ld. AO noted from the Balance Sheet of the assessee that it has received share application money of Rs.1,50,00,000/- including share premium of Rs.1,35,00,000/-. Assessee was asked to furnish details of the said share application

Lalwani Estates and Realtors Pvt Ltd, Manhar Villa, Anthony Road vs. ITO, 10 (2) (2), Aayekar Bhavan, Churchgate, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 3370/MUM/2023[2008-09]Status: DisposedITAT Mumbai08 Mar 2024AY 2008-09

Bench: Shri Narendra Kumar Choudhry, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 142(1)Section 143(1)Section 147Section 148

were to be companies controlled by Mr. Pravin Kumar Jain and indulged in providing accommodation entries. Above said three companies have paid share application money to the assessee %.10,00,000/- each during the current assessment year. Subsequently, further notices under section 142(1) of the Act dated 06.01.2016 were ... this connection, you are requested to submit the following: a. Details of shareholders, along with PAN, address, from whom such share application money has been received. Also furnish the details of time and mode of receipt b. Copy of receipt of duly filled share application forms from new investors