← All Phrases

“accommodation entry”

Cash Credits & Unexplained ItemsSection 68Section 684,509 judgments

The decision most relied on for accommodation entry is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on accommodation entry

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

McDowell & Co. Ltd. v. CTO
154 ITR 148 · 1985 · Supreme Court
741
citing judgments

The Supreme Court held that while legitimate tax planning is permissible, transactions structured as a "colourable device" or "subterfuge" solely to avoid tax are impermissible. It mandates a judicial shift to look beyond the form to the substance of a transaction, allowing the lifting of the corporate veil in tax evasion arrangements.

CIT v. Bholanath Poly Fab. Pvt. Ltd.
355 ITR 290 · 2013 · High Court
712
citing judgments

If an assessee makes purchases from bogus parties, but the underlying goods are genuinely acquired and sold, only the profit margin embedded in such purchases, and not the entire value of the bogus purchases, should be added to the assessee's income.

(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.

CIT v. Nikunj Exim Enterprises Pvt. Ltd.
372 ITR 619 · 2015 · High Court
391
citing judgments

Transactions defying human probability cannot be applied to isolated purchases if sales are accepted as genuine, and purchases cannot be disallowed without considering the entire transaction and documentary evidence. Failure to produce parties in an assessment proceeding may not be fatal to the assessee.

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

N.K. Proteins Ltd. v. DCIT
84 Taxmann.com 195 · 2017 · Supreme Court
204
citing judgments

When purchases are found to be entirely bogus and based on fictitious invoices from non-existent or unconfirmed suppliers, the entire amount of such purchases is liable to be added back as unexplained expenditure, not merely a percentage thereof.

Judgments citing accommodation entry

Nalini Vijay Shah, Ahmedabad vs. ITO Ward 3(1)(2), Ahmedabad

In the result, all appeals filed by the assessee are allowed for

ITA 1540/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad13 Mar 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Vivek Chavda, A.RFor Respondent: Ms. Neeju Gupta, Sr. DR
Section 115BSection 144Section 147Section 250Section 251(1)(a)Section 271(1)(c)

levied on the assessee for the impugned years under consideration. The Counsel for the assessee submitted that it is not a case of bogus accommodation entry on sale of penny stock, since the stock has been held by the assessee for a period of approximately four years, and therefore ... cannot be concluded that the assessee had taken a bogus accommodation entry. Accordingly, looking into the quantum of additions, and the assurance given by the Ld. Counsel for the assessee that if given an opportunity of hearing, the assessee shall duly / promptly comply with all notices of hearing

Nalini Vijay Shah, Satellite vs. Ward 3(1)(2) Ahmedabad, Ahmedabad

In the result, all appeals filed by the assessee are allowed for statistical purposes

ITA 1539/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad13 Mar 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Vivek Chavda, A.RFor Respondent: Ms. Neeju Gupta, Sr. DR
Section 115BSection 144Section 147Section 250Section 251Section 271(1)(c)

levied on the assessee for the impugned years under consideration. The Counsel for the assessee submitted that it is not a case of bogus accommodation entry on sale of penny stock, since the stock has been held by the assessee for a period of approximately four years, and therefore ... cannot be concluded that the assessee had taken a bogus accommodation entry. Accordingly, looking into the quantum of additions, and the assurance given by the Ld. Counsel for the assessee that if given an opportunity of hearing, the assessee shall duly / promptly comply with all notices of hearing

Shri Abhishek Lodha, Mumbai vs. ACIT Central Circle 1(3), Mumbai

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

ITA 6056/MUM/2024[2015-16]Status: DisposedITAT Mumbai13 Mar 2025AY 2015-16

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Shri. Abhishek Lodha Acit, Central Circle 1(3) C/O. Ketan H. Shah, Advocate, 512, Ayakar Bhavan, Mumbai – 400020. Times Square – 1, Opp. Ram Baug Vs. Bungalow, Thaltej Shilaj Road, Thaltej, Ahmedabad, Gujrat – 380059. Pan/Gir No. Aeqpl0917R (Assessee) : (Respondent) Assessee By : Shri. Aman Shah/Shri. Ketan Shah : Shri. Ram Krishn Kedia, (Sr. Dr) Respondent By Date Of Hearing : 11.03.2025 Date Of Pronouncement : 13.03.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) 47, Mumbai (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2015-16. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. In Issuing Notice U/S 148 Dated 05-09-2018 For The Ay 2015-16, It Is Said That, The Whole Proceeding Is Itself Bad In Law & Void & Further, There Is No Such Approval U/S 151 Of The Act & Therefore, The Proceeding Is Bad. 2. In Making Addition Of Rs. 7,63,706/- In Reference To The Commission Income, It Is Said That In View Of The Facts Of The Case, There Is No Evidence Regarding Earning Of Any Commission & Therefore, The Addition Is Required To Be Deleted. Shri. Abhishek Lodha

For Appellant: Shri. Aman Shah/Shri. Ketan Shah
Section 132Section 143(1)Section 143(2)Section 143(3)Section 148Section 151Section 153CSection 250

action u/s. 132 of the Act carried out in the case of Shri. Bhanwarlal Jain Group, dated 03.10.2013, who was alleged to be an accommodation entry provider in which the assessee was said to be one of the beneficiary of the bogus accommodation entries on account of commission amounting

ACIT-2(1)(1), Mumbai vs. Blue Circle Speciality Chemicals Pvt. Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

ITA 246/MUM/2024[2012-13]Status: DisposedITAT Mumbai13 Mar 2025AY 2012-13

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Haresh Shah, CAFor Respondent: Ms. Monika H.Pande, SR.DR
Section 132Section 133(6)Section 143(3)Section 148Section 68

deletion of addition made u/s. 68 of Rs.2.50 crores in respect of unsecured loans availed by the assessee which is alleged to be accommodation entry. 3. Brief facts of the case are that, assessee is engaged in the business of manufacturing of chemical products namely Saccharin, Sodium Saccharin ... basis of this search and seizure action, it is alleged that Shri Praveen Agarwal is one of the entry operators engaged in providing accommodation entries and assessee is one of the beneficiaries of the loan transaction availed by it from the following Companies as tabulated below: Sl. Name

Graceunited Developers Private Limited, Mumbai vs. Income Tax Officer-12(2)(1), Mumbai

In the result, both the appeals by the assessee are allowed

ITA 2049/MUM/2024[2014-15]Status: DisposedITAT Mumbai13 Mar 2025AY 2014-15

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Suchek Anchaliya, C.A. & Vaishali More, C.AFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 143(2)Section 147Section 148

Capital Gain (LTCG)/Loss. Shri Naresh Jain was discovered to be operating with his several associates to rig the stock market and to provide accommodation entries (in the form of bogus LTCG, bogus short term loss/gain) to various beneficiaries who intended to bring their unaccounted income into their books ... information it is seen that M/s. Graceunited Developers Private Limited PAN: AACCG6261E brings unaccounted Income into its books of account without paying taxes through accommodation entry in form of bogus long term capital gain or bogus short term capital gain form penny stock scrips. 4. Finding of the AO:- From

Graceunited Developes Private Limited, Mumbai vs. Income Tax Officer 12(2)(1), Mumba

In the result, both the appeals by the assessee are allowed

ITA 2048/MUM/2024[2013-14]Status: DisposedITAT Mumbai13 Mar 2025AY 2013-14

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Suchek Anchaliya, C.A. & Vaishali More, C.AFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 143(2)Section 147Section 148

Capital Gain (LTCG)/Loss. Shri Naresh Jain was discovered to be operating with his several associates to rig the stock market and to provide accommodation entries (in the form of bogus LTCG, bogus short term loss/gain) to various beneficiaries who intended to bring their unaccounted income into their books ... information it is seen that M/s. Graceunited Developers Private Limited PAN: AACCG6261E brings unaccounted Income into its books of account without paying taxes through accommodation entry in form of bogus long term capital gain or bogus short term capital gain form penny stock scrips. 4. Finding of the AO:- From

Shree Sadgurukrupa Buildcon Private Limited, Godhra vs. The Income Tax Officer, Ward-2, Godhra

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

ITA 973/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad12 Mar 2025AY 2010-11

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Kaushani Shah, A.RFor Respondent: Shri Ravindra, Sr. DR
Section 148Section 68

assessee company had not filed return of income for assessment year 2010-11. The assessing officer received information that the assessee had availed accommodation entry of ₹46,50,000/- from M/s Sarang Chemicals Limited, a bogus company managed by Shri Pratik Shah. In response to notice issued by the assessing ... Director of the company stated that M/s. Sarang Chemicals Ltd. was a paper company engaged the business of providing accommodation entries where cash or cheque were Shree Sadgurukrupa Buildcon Pvt. Ltd. vs. ITO Asst.Year –2010-11 - 4– received and no other activity was carried out by such company. Further

Jatin Shantilal Shah, Mumbai vs. Income Tax Officer, NFAC Delhi

Appeal is allowed

ITA 609/MUM/2025[2013-14]Status: DisposedITAT Mumbai12 Mar 2025AY 2013-14

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri N R Agarwal / Ms. Jenisha ShahFor Respondent: Ms. Kavitha Kaushik (SR DR)
Section 143(3)Section 147Section 148Section 250

held that the entire transaction in various companies where there are third party credits, debits, cash deposits, cash withdrawals, etc and which are considered accommodation entries, the income thereon is to be charged at the rate of 0.15 percentage of all transactions. The CIT(A) also erred in not considering ... amount of Rs.2,13,93,693/- .The assessment was completed, and assessee accepted that assessee acted as an exit provider and giving the accommodation entry to different beneficiariesrelated to the shares of the two parties, “M/s Gemstone International” and “Nivyah Infrastructure and “M/s Nivyah Infrastructure”. The assessee accepted that

Jatin Shantilal Shah, Mumbai vs. Income Tax Officer, ITO Mumbai

Appeal is allowed

ITA 584/MUM/2025[2012-13]Status: DisposedITAT Mumbai12 Mar 2025AY 2012-13

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri N R Agarwal / Ms. Jenisha ShahFor Respondent: Ms. Kavitha Kaushik (SR DR)
Section 143(3)Section 147Section 148Section 250

held that the entire transaction in various companies where there are third party credits, debits, cash deposits, cash withdrawals, etc and which are considered accommodation entries, the income thereon is to be charged at the rate of 0.15 percentage of all transactions. The CIT(A) also erred in not considering ... amount of Rs.2,13,93,693/- .The assessment was completed, and assessee accepted that assessee acted as an exit provider and giving the accommodation entry to different beneficiariesrelated to the shares of the two parties, “M/s Gemstone International” and “Nivyah Infrastructure and “M/s Nivyah Infrastructure”. The assessee accepted that

ITO, Ward-4(4), Gurgaon vs. Tribhawan Kumar Parnami, Gurgaon

ITA 2120/DEL/2018[2009-10]Status: DisposedITAT Delhi12 Mar 2025AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 143(3)Section 153A

Unique Maintenance Pvt. Ltd. and M/s Kartikey Builders. From the assessment order it is also noticed that there is no allegation of obtaining any accommodation entry from any entry operator or utilization of any undisclosed cash for the purpose of obtaining the above funds and routing it for payment

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 901/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 2 Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified ... without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? Kedia Builders and Colonizers Pvt. Ltd., Jaipur 2 Whether on the facts and circumstances of the case

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 875/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 2 Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified ... without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 3 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur 2 Whether on the facts

Income Tax Officer (Gopal Lal Kansotia), Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 874/JPR/2024[2015-16]Status: DisposedITAT Jaipur11 Mar 2025AY 2015-16
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 2 Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified ... without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 2.3 2.4 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur 2 Whether

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

ITA 873/JPR/2024[2013-14]Status: DisposedITAT Jaipur11 Mar 2025AY 2013-14
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 2 Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified ... without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 2 Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 872/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Mar 2025AY 2012-13
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? 2 Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified ... without appreciating the facts and circumstances of the case ignoring that the assessee was involved in organized tax evasion by taking bogus accommodation entry and also has paid commission for taking accommodation entry? ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur 2 Whether on the facts

M/S.Aaryavart Infrastructure Pvt. Ltd., Ahmedabad vs. The DCIT, Circle-1(1)(1) Presently Central Circle-1(3), Ahmedabad

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

ITA 219/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad11 Mar 2025AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.219/Ahd/2022 िनधा"रण वष" /Assessment Year : 2012-13 Aaryavart Infrastructure Pvt. Ltd. Dy.Cit बनाम/ Ff – 17/A, Pariseema Complex Circle-1(1)(1) V/S. C.G. Road Presently Cen. Cir.1(3) Navrangpura Ahmedabad Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aadca 4844 Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Aseem Thakkar, Ar Revenue By : Shri Kavan Limbasiya, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 07/03/2025 घोषणा की तारीख /Date Of Pronouncement: 11/03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-11, Ahmedabad [Hereinafter Referred To As “Cit(A)”], Dated 30.03.2022, For The Assessment Year (Ay) 2012-13, Whereby The Cit(A) Has Confirmed The Additions Made By The Assessing Officer [Hereinafter Referred To As “Ao”] Under Section 68 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”]. Aaryavart Infrastructure Pvt.Ltd. Vs. Dcit Asst. Year : 2012-13

For Appellant: Shri Aseem Thakkar, ARFor Respondent: Shri Kavan Limbasiya, Sr. DR
Section 143(3)Section 2(24)(x)Section 40Section 68

bank statement of Narayan P. Ahuja showed a cash deposit of Rs.10,00,000/- before issuing the loan to the assessee, suggesting accommodation entry. - The confirmation letter from Supreme Gold, another lender, was unsigned, and no sufficient evidence regarding the lender’s creditworthiness was furnished. 4. Aggrieved by the order

Idris Mikdad Attarwala, Mumbai vs. ACIT Central Circle 3(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 75/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Mar 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankaridris Mikdad Attarwala, V/S. Assistant Commissioner Of 1603 Sumer Park, Seth बनाम Income Tax, Central Circle – Motishah X Lane, Byculla, 3(1), Kautilya Bhavan, C-41 To Mumbai 400 027, C-43, G-Block, Bandra Kurla Maharashtra Complex, Bandra(E) Mumbai - 400051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Abupa1037C Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Ajay R. Singh & Shri A.Pawar,ARsFor Respondent: Shri Mahesh Pamnani,(Sr. DR)
Section 133ASection 147Section 148

income. In the subsequent appeal, the ld.CIT(A) upheld the addition holding that the investigation revealed that impugned purchase was merely an accommodation entry and supporting evidences filed were irrelevant. Moreover, the assessee failed to furnish any evidence before him in support of the said transaction. 4. Before us, while

Sharp Business Systems (India) Pvt. Ltd., New Delhi vs. DCIT, New Delhi

ITA 717/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Mar 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Sh. Vinay Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdqps4406L (Appellant) (Respondent) With C.O. No.60/Del/2019 [Arising Out Of Ita No.712/Del/2019] Assessment Year: 2011-12 Vs. Dcit, Sh. Vinay Sharma, B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdqps4406L (Appellant) (Respondent) With Ita Nos.716 & 717/Del/2019 Assessment Years: 2011-12 & 2012-13 Vs. Sh. Dheer Chand Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdlps0502C (Appellant) (Respondent) With C.O. Nos.64 & 65/Del/2019 [Arising Out Of Ita Nos.716 & 717/Del/2019] Assessment Years: 2011-12 & 2012-13 Vs. Dcit, Sh. Dheer Chand Sharma B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdlps0502C (Appellant) (Respondent)

Section 144Section 153ASection 37(1)

Rs.3,87,142/-; respectively as against the CIT(A)’s lower appellate discussion directing him to restrict the same @ 2.5% thereof since representing accommodation entries provided to M/s. NKG Infrastructure Limited in the form of sales; reading as under: “9. I have considered the facts and circumstances of the case ... next day. Thereby, it is clear that all the Sharma group of cases were used by M/s NKG Infrastructure P. Ltd. to get accommodation entries. This fact was also confirmed by Sh. Guruprasad Sharma and Sh. Dheechand Sharma under the statement recorded under section

ACIT, Jaipur vs. Udai Buildhome Pvt Ltd, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1486/JPR/2024[2018]Status: DisposedITAT Jaipur10 Mar 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, JM आयकर अपील सं. / ITA Nos.1399, 1400, 1401 & 1486/JP/2024 निर्धारण वर्ष / Assessment Years : 2014-15, 2015-16, 2017-18 & 2018-19 Asstt. Commissioner of Income Tax, Central Circle-02, Jaipur बनाम Vs. M/s Udai Buildhome Pvt. Ltd. 302, Golden Sunrise Apartment, Lajpat Marg, C- Scheme, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCU 5068 J अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by: प्रत्यर्थी / Respond

For Appellant: Sh. C.M. Agarwal, CAFor Respondent: Smt. Roshanta Meena, CIT
Section 143(3)Section 153C

almost exclusively utilizing all this capital for extending loans & advances and/or investing in unlisted equities. This is typical of paper companies that provide accommodation entries out of bogus unsecured loans and share premium in their accounts. Also, wild and unexplained fluctuations in the declared turnover of above referred Companies would ... company which has no business activity and no existence. Thus, the unsecured loan shown by the assessee from M/s Inner Mercantile Pvt. Ltd. is accommodation entry only. Accordingly, assessee was show caused vide order sheet entry dated 18-12-2019 as ACIT vs. M/s Udai Buildhome

ACIT, Jaipur vs. Udai Buildhome Pvt Ltd, Jaipur

ITA 1401/JPR/2024[2017]Status: DisposedITAT Jaipur10 Mar 2025
For Appellant: Sh. C.M. Agarwal, CAFor Respondent: Smt. Roshanta Meena, CIT
Section 143(3)Section 153C

almost exclusively utilizing all this capital for extending loans & advances and/or investing in unlisted equities. This is typical of paper companies that provide accommodation entries out of bogus unsecured loans and share premium in their accounts. Also, wild and unexplained fluctuations in the declared turnover of above referred Companies would ... company which has no business activity and no existence. Thus, the unsecured loan shown by the assessee from M/s Inner Mercantile Pvt. Ltd. is accommodation entry only. Accordingly, assessee was show caused vide order sheet entry dated 18-12-2019 as why the unsecured loan shown to be received should