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“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

Income Tax Officer, Ward-1(8), Bhavnagar vs. Alinaqi Gulamabbas Bhimani, Bhavnagar

The appeal of the Revenue is treated as allowed for statistical purposes

ITA 2140/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2140/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Income Tax Officer Alinaqi Gulamabbas Bhimani बनाम/ Ward-1(8) Prop. Of United Steel V/S. Bhavnagar – 364 001 Corporation Nr. Bajrangdas Dada Ni Vav At Sihor Dist. Bhavnagar – 364 240 "थायी लेखा सं./Pan: Bljpb 9200 L (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Varis Isani, Advocate Revenue By : Shri Arvind Kumbhare, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 20/01/2026 घोषणा की तारीख /Date Of Pronouncement: 28/01/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Varis Isani, AdvocateFor Respondent: Shri Arvind Kumbhare, Sr.DR
Section 115BSection 133ASection 147Section 250Section 68

fact that assessee had made bogus purchases from M/s. India Steel Impex, whose proprietor, Shri Bhaveshkumar Bhogilal Patel, admitted under oath to issuing accommodation entries? 2. The appellant craves leave to amend or alter any ground or add a new ground, which may be necessary. 3. It is, therefore, prayed ... Patel. A survey was conducted u/s.133A of the Act on Shri Bhaveshkumar Bhogilal Patel during which he made a statement that he was providing accommodation entries to various beneficiaries. The assessee was also found to be one of the beneficiaries, who allegedly had obtained accommodation entry of bogus purchases

DCIT, Cr Building vs. Gulshan Polyols Limited, Laxmi Nagar

In the result, the appeal filed by the Revenue is dismissed

ITA 5551/DEL/2024[2019-20]Status: DisposedITAT Delhi28 Jan 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmadcit (Osd), Range 10, Vs. M/S. Gulshan Polyols Limited, New Delhi. G – 81, Preet Vihar, Anand Vihar, East Delhi, Delhi – 110 092. (Pan : Aabcg3954F) Co No.47/Del/2025 (In Ita No.5551/Del/2024) (Assessment Year: 2019-20) M/S. Gulshan Polyols Limited, Vs. Dcit (Osd), Range 10, G – 81, Preet Vihar, New Delhi. Anand Vihar, East Delhi, Delhi – 110 092. (Pan : Aabcg3954F) (Appellant) (Respondent) Assessee By : Mohd. Shahid, Ca Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 10.11.2025 Date Of Order : 28.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [“Ld. Cit (A)”, For Short] Dated 29.11.2024 For The Assessment Year

For Appellant: Mohd. Shahid, CAFor Respondent: Shri Rajesh Kumar Dhanesta, SR. DR
Section 133(6)Section 133ASection 143(2)Section 148ASection 68Section 69C

year. 2. Brief facts of the case are, the case of the assessee was selected for the reason that Assessing Officer had information about accommodation entry provided by the assessee. Assessee had filed its return of income declaring total income of Rs.23,69,10,390/-. The Assessing Officer observed that ... case of Ashok Kumar Gupta and others. In the survey proceedings, they have admitted that they had provided both sale and purchase of accommodation entries which were provided to various beneficiaries. Accordingly, notices u/s 143(2) and 142(1) were issued and served on the assessee. In response, assessee

Oracle Granito Limited, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

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

ITA 2432/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad27 Jan 2026AY 2019-20

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2432/Ahd/2025 िनधा"रण वष" /Assessment Year : 2019-20 Oracle Granito Limited The Dcit, Circle-3(1)(1) बनाम/ 206, Dev Arc, 2Nd Floor Ambawadi V/S. Nr. Fun Republic Ahmedabad- 38015 Opp. Big Bazar S.G. Highway Road Ahmedabad- 380 015 "थायी लेखा सं./Pan: Aaaco 6238 P (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Aseem L. Thakkar, Ar Revenue By : Shri Rohit Aasudani, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/01/2026 घोषणा की तारीख /Date Of Pronouncement: 27/01/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 10/10/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2019-2020. 2. The Assessee, In This Appeal, Is Aggrieved By The Action Of The Ld.Cit(A) In Confirming The Addition Made By The Assessing Officer (Ao) Of Oracle Granito Ltd. Vs. Dcit Asst. Year : 2019-20

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Rohit Aasudani, Sr.DR
Section 147Section 250

Assessing Officer (AO) of Oracle Granito Ltd. vs. DCIT Asst. Year : 2019-20 Rs.2,00,184/-, allegedly received by the assessee as an accommodation entry through “Radhika & Brothers” an associate-concern of Sanjay Govindram Agarwal. As per the information available to the AO, the said concern was involved in providing ... accommodation entries and the assessee had received accommodation entries from the said concern of Rs.2,00,184/-. The AO, therefore, reopened the assessment of the assessee u/s.147 of the Act. 3. During the assessment proceedings, the assessee denied to have received any such accommodation entry. The AO, however, referred

Luvkesh Textile Industries Pvt Ltd, Mumbai vs. DCIT Circle 4(2)(1), Mumbai

In the result the both the appeals are allowed for statistical purposes

ITA 6054/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarluvkesh Textile Industries Pvt. Deputy Commissioner Ltd. Of Income Tax Circle 201, Maxheal House, Swami 4(2)(1) Vs. Ayyappa Mandir Marg, Bangur Aayakar Bhavan, Nagar, Goregaon West, Maharishi Karve Road, Mumbai - 400104 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Deputy Commissioner Of Lukesh Textile Industries Income Tax Circle Private Limited 4(2)(1) Vs. 21/22 A Chunawal Ind Estate, 640 Aayakar Bhavan, Condivita Lane, Andheri East, Maharishi Karve Road, Mumbai - 400020 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Present For: Assessee By : Shri A. L. Sharma, Ar Revenue By : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 04.12.2025 Date Of Pronouncement : 27.01.2026 आदेश / O R D E R Per Prabhash Shankar [A.M.] :- The Instant Appeals Have Been Preferred By Both The Assessee & The Revenue Which Emanate From The Appellate Order Passed By The Ld. Cit(A)/National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As “Cit(A)”] With Regard To The Assessment Order Passed Under Luvkesh Textile Industries Pvt. Ltd. Section 147 R.W.S. 144 Of The Income Tax Act 1961, (In Short ‘The Act’) Dated 22.03.2024 A.Y. 2018-19. 2. The Revenue Has Raised Following Grounds Of Appeal :

For Appellant: Shri A. L. Sharma, ARFor Respondent: Shri Surendra Mohan, Sr. DR
Section 131Section 147Section 69C

bogus purchases, without appreciating the facts that there was no physical delivery of goods and the purchases claimed by the assessee are nothing but accommodation entries. 2. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in restricting the addition ... addition of Rs.8,16,24,351/- was made on account of alleged non-genuine purchases from certain parties suspected to be engaged in issuing accommodation entries. The assessee is engaged in the business of trading in fabrics. During the year under consideration, it made purchases from several parties, including

DCIT-421, Mumbai vs. Lukesh Textile Industries Private Limited, Mumbai

In the result the both the appeals are allowed for statistical purposes

ITA 5924/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarluvkesh Textile Industries Pvt. Deputy Commissioner Ltd. Of Income Tax Circle 201, Maxheal House, Swami 4(2)(1) Vs. Ayyappa Mandir Marg, Bangur Aayakar Bhavan, Nagar, Goregaon West, Maharishi Karve Road, Mumbai - 400104 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Deputy Commissioner Of Lukesh Textile Industries Income Tax Circle Private Limited 4(2)(1) Vs. 21/22 A Chunawal Ind Estate, 640 Aayakar Bhavan, Condivita Lane, Andheri East, Maharishi Karve Road, Mumbai - 400020 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Present For: Assessee By : Shri A. L. Sharma, Ar Revenue By : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 04.12.2025 Date Of Pronouncement : 27.01.2026 आदेश / O R D E R Per Prabhash Shankar [A.M.] :- The Instant Appeals Have Been Preferred By Both The Assessee & The Revenue Which Emanate From The Appellate Order Passed By The Ld. Cit(A)/National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As “Cit(A)”] With Regard To The Assessment Order Passed Under Luvkesh Textile Industries Pvt. Ltd. Section 147 R.W.S. 144 Of The Income Tax Act 1961, (In Short ‘The Act’) Dated 22.03.2024 A.Y. 2018-19. 2. The Revenue Has Raised Following Grounds Of Appeal :

For Appellant: Shri A. L. Sharma, ARFor Respondent: Shri Surendra Mohan, Sr. DR
Section 131Section 147Section 69C

bogus purchases, without appreciating the facts that there was no physical delivery of goods and the purchases claimed by the assessee are nothing but accommodation entries. 2. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in restricting the addition ... addition of Rs.8,16,24,351/- was made on account of alleged non-genuine purchases from certain parties suspected to be engaged in issuing accommodation entries. The assessee is engaged in the business of trading in fabrics. During the year under consideration, it made purchases from several parties, including