“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

Dy.CIT, Circle-7(1)(1), Mumbai vs. Needful Dealcom Pvt. Ltd., Mumbai

In the result, both the appeals filed by the Revenue are dismissed

ITA 2940/MUM/2023[2012]Status: DisposedITAT Mumbai05 Aug 2024

Bench: Justice (Retd.) Shri C.V. Bhadang, Hon’Ble & Shri B.R. Baskaran, Hon’Ble

For Appellant: Shri J.P. Bairagra &For Respondent: Shri S. Srinivasu, CIT-DR

Section 143(3)Section 147Section 148Section 68

mean time, the AO received information from the Investigation Wing, Kolkattathat the assessee has received above mentioned share application money by way of accommodation entries from some of the companies managed by a person named Shri Subhash Chandra Bhartia. The above said Shri Subhash Chandra Bhartia was subjected to search ... survey operation and in the statement recorded from him, he had admitted that he is involved in the activities of providing accommodation entries in the guise of share application money. On the basis of the above said information, the AO re-opened the assessment of the current year by issuing

ITO-24(1)(1), Mumbai vs. Drapewell Garments, Mumbai

ITA 1347/MUM/2024[2012-13]Status: DisposedITAT Mumbai02 Aug 2024AY 2012-13

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Himanshu Sharma (CIT DR)

Section 115Section 132Section 132(4)Section 142(1)Section 143(1)Section 143(3)Section 148

search M/s. confidence Finance and Trading Ltd. (CFATL) wherein the company has admitted u/s 132(4) of the Act to have indulged in providing accommodation entries to various beneficiaries in the form of loans and to facilitate introduction of unaccounted income of members of beneficiaries in the form of exempt ... justified in not upholding the addition made by the A.O. even though it is well established that the modus operandi of obtaining accommodation entries of unsecured loan had to be considered in the light of surrounding circumstances, normal course of human conduct and preponderance of probability?" 4. Whether

Suvidha Buildtech Pvt Ltd, Delhi vs. ACIT Central Circle-13, Delhi

In the result, both the appeals of the assessee are dismissed

ITA 1366/DEL/2023[2013-14]Status: DisposedITAT Delhi02 Aug 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: NoneFor Respondent: Shri N. K. Bansal, Sr. DR

Section 153CSection 153D

Aggarwal and Shri Mukesh Kumar and Others” Group of cases based at Delhi. This group was found to be group of entry operators providing accommodation entries to beneficiaries. The ld. AO had noted that during the course of search and seizure operation, many incriminating papers/ documents were found related ... determining total income of Rs. 53,91,550/-. In the assessment, following additions were made:- a. commission income of accommodation entries on substantive basis @2% of amount of share capital, share premium, loans and advances and investments and b. commission income @1% on bogus purchases and sales is being made

Suvidha Buildtech Pvt Ltd, Delhi vs. ACIT Central Circle-13, Delhi

In the result, both the appeals of the assessee are dismissed

ITA 1365/DEL/2023[2012-13]Status: DisposedITAT Delhi02 Aug 2024AY 2012-13

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: NoneFor Respondent: Shri N. K. Bansal, Sr. DR

Section 153CSection 153D

Allied Engineers and Elastomers, Mumbai vs. Income Tax Officer 18(1)(1), Mumbai

In the result, the appeals of the assessee is allowed

ITA 1687/MUM/2024[2009-10]Status: DisposedITAT Mumbai01 Aug 2024AY 2009-10

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Dr. K. Shivaram a/w Shri Rahul KFor Respondent: Shri R.R. Makwana, Sr. DR

Section 143(1)Section 143(3)Section 147Section 148Section 234ASection 69C

opened for the second time based on the information that Mr. Harish K. Chandak the proprietor of M/s Giriraj Enterprises has admitted to providing accommodation entry and that the assessee has entered into transactions to the tune of Rs.1,22,63,975/- with the said enterprise. The AO made ... without any independent enquiry and without any tangible material in the hands of the AO to show that the assessee was involved in taking accommodation entry towards bogus purchases. Considering the facts unique to the facts and circumstances of the present case we hold that the AO could not have

Kunal Tejesh Gandhi, Mumbai vs. Income Tax Officer 25(2)(5), Mumbai

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

ITA 3913/MUM/2023[2012-13]Status: DisposedITAT Mumbai01 Aug 2024AY 2012-13

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm Kunal Tejesh Gandhi Ito-25(2)(5) 2Nd Floor, Shehnaz Building, Mumbai Samarth Ramdas Road, Jvpd, Vs. 10Th Road, Juhu, Mumbai – 400 049

For Appellant: Shri Yogesh TharFor Respondent: Shri P. D. Chougule

Section 143(3)Section 147Section 148Section 250Section 68

dated 23.09.2016 as per the information received from the Investigation Wing that the assessee was one of the beneficiary of accommodation entries provided by the group entities of Shri Anil Agarwal by way of LTCG on sale of shares. The ld. A.O. then passed the assessment order ... broker by name M/s.JHP Securities P. Ltd. which according to the ld. AR was not alleged by the department to have engaged in providing accommodation entries. The ld. AR also contended that the ld. A.O. has specified about Shri Manish Waghela and Shri Sachin Kadam who is said to have

Arvindkumar Amulkh Tanna, Ahmedabad vs. The ACIT, Central Circle-2 (3), Ahmeadabad

ITA 577/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

Section 132Section 143(1)Section 143(3)Section 153A

appellant order that “the AO to be appears be justified in holding that either these loans are sham / fictitious or mere accommodation entries and whatever be the actual facts, are hit by the provisions of section 68/69A of the Act because based on the investigations made and the findings therefrom ... merits also. While no incriminating material was found during the search to hold that the losses accrued to the appellant were bogus/fictitious or accommodation entries, it is also the fact that during the search no tangible assets in form of cash, jewellery or any other assets were found which could

Shreem Electric Limited, Kolhapur vs. ACIT Central Circle, Kolhapur

In the result, appeal of the assessee is allowed

ITA 898/PUN/2024[2017-18]Status: DisposedITAT Pune31 Jul 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.898/Pun/2024 िनधा"रण वष" / Assessment Year:2017-18 Shreem Electric Limited, V The Assistant Plot No.43 To 46, S Commissioner Of Income L.K.Akiwate Industrial Tax, Estate, Jaysingpur, Shirol, Central Circle, Kolhapur. Kolhapur – 416144. Pan: Aaccs4893C Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Shri Sourabh Nayak -Addl.Cit(Dr) Date Of Hearing 31/07/2024 Date Of Pronouncement 31/07/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11Passed Under Section 250 Of The Income Tax Act, Dated 31.01.2024 For The A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Confirming Penalty Under Section 270A Of Rs.3,01,124/-. Shreem Electric Limited, Kolhapur[A] 2. The Learned Cit(A) Failed To Appreciate That, Since The Addition Is Made On Adhoc Basis, No Penalty Can Be Levied. 3. The Penalty Levied May Please Be Delete. 4. The Appellant Craves Leave To Add, Alter, Amend Or Delete Any Of The Above Grounds Of Appeal.” 2. There Is A Delay Of Two Months Of Filing Appeal Before This Tribunal. Considering The Reasons Mentioned In The Affidavit, We Are Convinced With The Reasons For Delay & In The Larger Interest Of Justice, We Condone The Delay.

Section 250Section 270ASection 270A(6)

income. The assessee’s case was reopened for A.Y.2017-18 for the alleged reasons that assessee had 2 Shreem Electric Limited, Kolhapur[A] received accommodation entry from M/s.ABN Trade Link Pvt. Limited. During the assessment proceedings, assessee submitted an affidavit that there were no purchases from ABN Trade Link ... year. Therefore, the Assessing Officer(AO) sought information from the Investigation Wing, Mumbai. The Investigation Wing, Mumbai submitted that M/s.RadianceMultitrade Pvt. Ltd., had provided accommodation entries of Rs.1,26,32,550/- to M/s.Shreem Electric Ltd., for F.Y.2016-17. The assessee was asked to file a reply by the Assessing Officer

Rahul Chandrakant Jhaveri, Mumbai vs. DCIT, Central Circle 8(2), Mumbai

In the result, all these appeals are allowed in accordance with the above direction

ITA 4513/MUM/2023[2018-19]Status: DisposedITAT Mumbai31 Jul 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Rashmikant Modi, CA &For Respondent: Shri Manish Sareen, CIT, DR

Section 132Section 142(1)Section 144Section 145(3)Section 153Section 153A

being 5% of Rs. 13,55,73,00,667/- i.e. aggregate of debit transactions and credit transactions of the bank statement as accommodation entries without considering the statement of the Appellant recorded during the course of search and reproduced by the Learned Assessing Officer in the assessment order. The Appellant ... days. There is sufficient reason also that the assessee is met with the huge demand of Rs. 525 crores and is an accommodation entry provider who has given the bills to the One World Group. It is also apparent that assessee was running several proprietary concerns by giving bogus bills

DCIT CC, 4(3), Mumbai vs. Nouveau Global Ventures Limited, Mumbai

ITA 3611/MUM/2023[2010-11]Status: DisposedITAT Mumbai31 Jul 2024AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Ashok Bansal, &For Respondent: Mr. S. Srinivasu, CIT-DR &

Section 132Section 153CSection 68

case of 'sh Rajkumar Kedia' Group on 13.06.2014, it was found that share/scrip of the assessee company had been misused for providing accommodation entries in the form of bogus long term capital gain (LTCG) to beneficiaries and short term capital loss (STCL) to exit providers. The Assessing Officer has referred ... also referred to the statement of other persons including sh Suresh Jajodiya, Mumbai and Shri Anil Kumar Mittal, Mumbai, who were engaged in providing accommodation entries of LTCG in other scrips with the help of Shri R.K. Kedia. The Assessing Officer analyzed artificial raising of the price of the shares

DCIT CC, 4(3), Mumbai vs. Nouveau Global Ventures Limited, Mumbai

ITA 3609/MUM/2023[2011-12]Status: DisposedITAT Mumbai31 Jul 2024AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Ashok Bansal, &For Respondent: Mr. S. Srinivasu, CIT-DR &

Section 132Section 153CSection 68

DCIT CC, 4(3), Mumbai vs. Nouveau Global Ventures Limited, Mumbai

In the result, the appeals of the Revenue are allowed for statistical purposes whereas cross statistical purposes whereas cross-objections of the assessee are of the assessee are dismissed

ITA 3608/MUM/2023[2012-13]Status: DisposedITAT Mumbai31 Jul 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Ashok Bansal, &For Respondent: Mr. S. Srinivasu, CIT-DR &

Section 153CSection 68

found that it was found that share/scrip of the assessee comp crip of the assessee company had been misused for been misused for providing accommodation entries in the form of bogus long term providing accommodation entries in the form of bogus long term providing accommodation entries in the form ... Suresh Jajodiya, sh Suresh Jajodiya, Mumbai and Shri Anil Kumar Mittal Shri Anil Kumar Mittal, Mumbai , who , Mumbai , who were engaged in providing accommodation entries of in providing accommodation entries of LTCG in other s in other scrips with the help of Shri R.K. Kedia. The Assessing Officer analyzed Shri

DCIT Central Circle-13, New Delhi vs. Bar Investments and Finance Private Limited, New Delhi

In the result, the appeal of revenue is dismissed

ITA 2165/DEL/2023[2016-17]Status: DisposedITAT Delhi31 Jul 2024AY 2016-17

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2016-17 Dcit, Vs. Bar Investments & Central Circle – 13, Finance Private Limited B- New Delhi 64/1, Wazirpur Industrial Area, New Delhi-110052 Pan No. Aaacb0955E (Appellant) (Respondent) Appellant By Sh. Sanjay Kumar, Cit Dr Respondent By Sh. Pradeep Dinodia,Ca Sh. R.K. Kapoor, Ca Sh. Ravi Kumar, Ca Sh. Harish Dhamija, Ca Date Of Hearing: 18/07/2024 Date Of Pronouncement: 31/07/2024 Order Per Sudhir Kumar, Jm:

Section 143(2)Section 143(3)Section 68

under :- “6.2 Considering the findings discussed in para-5.3 above and also since there is no evidence on record that the appellant has taken accommodation entry, the addition made by the AO is not sustainable in the eye of law. Hence, the addition of Rs.16,16,000 made

M/S. Kuber Tie-Up Pvt. Ltd, Kolkata vs. ACIT(OSD), Ward- 2(3), Kolkata.

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

ITA 1371/KOL/2023[2010-11]Status: DisposedITAT Kolkata30 Jul 2024AY 2010-11

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. No.1371/Kol/2023 Assessment Years: 2010-11 M/S Kuber Tie-Up Pvt. Ltd……………....................…...……………....Appellant 16, Gandhi House, Ganesh Chandra Avenue, 8Th Floor, Kolkata-13. [Pan: Aacck6127H] Vs. Acit(Osd), Ward-2(3), Kolkata.………............................…..…..... Respondent Appearances By: Shri Sanket Joshi, Ca, Appeared On Behalf Of The Assessee. Shri Sailen Samadder, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : June 05, 2024 Date Of Pronouncing The Order : July 30, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 25.05.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Appeal Is Time-Barred By 142 Days. A Separate Application For Condonation Of Delay Has Been Filed, Wherein, It Has Been Pleaded That The Impugned Order Of The Cit(A) Was Not Physically Served Upon The Assessee. The Order Was Sent On Email, However, The Said Email Was Not Noticed By The Assessee, Therefore, The Assessee Did Not Come To The Knowledge Of The Passing Of The Impugned Order Of The Cit(A). The Passing Of The Order Of The Cit(A) Came To The Knowledge Of The Assessee Only On October 2023. Thereafter, The Assessee Regularly Approached His Consultant To File The Appeal, However, The Consultant Was Busy In Return Filing Activity & Did Not File The Appeal. Thereafter, The Assessee

Section 144Section 148Section 151Section 250

Counsel has further submitted that the allegation in the assessment order is that the assessee had received unexplained income by way of accommodation entry of Rs.1,65,30,000/- from M/s. G. D Enterprises in its bank account. The ld. Counsel has pleaded that there was some mis-information

Shri Vikram N. Chandan, Mumbai vs. ITO, 19(3)(5), Mumbai

In the result, appeal of the assessee is allowed

ITA 70/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Jul 2024AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2015-16

For Appellant: Shri Neelkanth Khandelwal, CAFor Respondent: Ms. Rajeshwari Menon, Sr. DR

Section 10(38)Section 143(2)Section 143(3)Section 68Section 69C

complied. Ld. Assessing Officer also referred to statement of one Mr. Anuj Agarwal who according to him was running the racket of providing accommodation entries by manipulating the share prices of alleged penny scrip of the PS IT. Ld. Assessing Officer noted that statement of Mr Anuj Agarwal was recorded ... Chandan., AY 2015-16 the course of survey operation under section 133A by the DDIT (Inv.), Kolkata to state that he had provided accommodation entries in the alleged penny scrip. 4.1. Assessee had submitted that transaction in the said shares were subjected to STT levy and consideration of sale

Mahavir Metal and Alloys, Mumbai vs. Income Tax Officer, Matrumandir Nana Chowk, Mumbai

ITA 3008/MUM/2023[2011-2012]Status: DisposedITAT Mumbai30 Jul 2024AY 2011-2012

Bench: MS. PADMAVATHY S, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Respondent: Shri Nayanjyoti Nath

Section 143(3)Section 147Section 148Section 250Section 68

addition of Rs.20,00,000/- as unexplained cash credit to its taxable income for the assessment year 2011-12 on account of an accommodation entry received from SUN DIAM. 3. However, the Appellant has presented evidence that this particular loan transaction was in the normal course of business hence ... Dharmichand Jain and their Group Concerns on 3.10.2013. During the course of search/survey action, it was revealed that these group concerns were merely providing accommodation entries through various benami concerns operated and managed by them. It was also found that these concerns are indulged into fraudulent transactions of issuing accommodation/hawala

Shree Shiromani Project Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 106/KOL/2024[2013-14]Status: DisposedITAT Kolkata29 Jul 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.106/Kol/2024 Assessment Year: 2013-14 Shree Shiromani Project Pvt. Ltd. ...……………………....………....Appellant C/O Advocate Amit Agarwal, 50D, Mukta Ram Babu Street, 4Th Floor, Kolkata – 700007. [Pan: Aabcv0376L] Vs. Ito, Ward-2(1), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Amit Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri Kallol Mistry, Jcit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 22, 2024 Date Of Pronouncing The Order : July 29, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 21.03.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. That The Learned National Faceless Appeal Centre, Delhi Erred In Passing Ex-Parte Order Dated 21St March, 2023 Under Section 250 Of The Income Tax Act, 1961 Dismissing The Appeal Of The Appellant In Liminie Without Dealing With The Merits Of The Case & By Not Passing Order On The Grounds Of Appeal Raised By The Appellant Assessee Company Against The Impugned Assessment Order Dated 30.09.2021 Passed By The Assessing Officer Under Section 147 R.W.S 144 Of The Income Tax Act

Section 147Section 250Section 68

further the amount of Rs.26,00,000/- has been added into the income of the assessee by the Assessing Officer on account of accommodation entry received by the assessee on account of bogus share transaction. 4. The assessee has not only contested the validity of the reopening of the assessment

M/S Venkateswar Medicare Pvt. Ltd., ITO, Ward-2(1) vs. ITO, Ward-2(1), Kolkata

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

ITA 1417/KOL/2023[2016-17]Status: DisposedITAT Kolkata29 Jul 2024AY 2016-17

Bench: Shri Rajesh Kumar, Am& Shri Sonjoy Sarma, Jm]

Section 119Section 143(2)Section 144BSection 147Section 148Section 148ASection 68

filed the return of income declaring total income of Rs.39,72,460/-. Thereafter, the AO received information that the assessee is a beneficiary of accommodation entries from Shri Mukesh Banka to the tune of Rs.92,50,000/- during the current financial year and accordingly, the case of the assessee ... submitted that as per the reasons recorded by the Ld. AO, it was noted that assessee has received and is beneficiary of accommodation entry amounting to Rs.92,50,000/- received from the concerns belonging to or operated by Shri Mukesh Banka during the year and accordingly, the Ld. AO came

M/S Venkateswar Medicare Pvt. Ltd., Kolkata vs. ITO, Ward 2(1), Kolkata

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

ITA 1416/KOL/2023[2014-15]Status: DisposedITAT Kolkata29 Jul 2024AY 2014-15

Bench: Shri Rajesh Kumar, Am& Shri Sonjoy Sarma, Jm]

Section 119Section 143(2)Section 144BSection 147Section 148Section 148ASection 68

ITO-11(1)(1), Mumbai vs. Sandesh Projects Private Limited, Mumbai

The appeal of the AO are dismissed

ITA 2305/MUM/2024[2010-11]Status: DisposedITAT Mumbai29 Jul 2024AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm The Income Tax Officer Vs. Sandesh Projects Private Limited Ward 11 (1) (1) Unit Number 242, B Wing Room Number 201, Sanjoy Building – 5, Aaykar Bhavan Mittal Industrial Estate Mumbai Andheri Kurla Road Andheri (E) Mumbai – 59 (Appellant) (Respondent) Pan No. Aamcs2433E

For Appellant: Shri Rajnish Yadav , SR DRFor Respondent: none

Section 133Section 143Section 147Section 148Section 68

This return was processed under section 143 (1) of the act on 14/4/2011. Subsequently the information was received that assessee has obtained accommodation entry from Praveen Jain and group companies out of the search action carried out on 1/10/2013. The assessee is found to be the beneficiary by receiving ... said application money from 2 companies operated by the accommodation entry provider of Rs 23 lakhs each. Thus, the learned assessing officer recorded the satisfaction that he has reason to believe that income chargeable to tax amounting to Rs 46 lakhs have escaped assessment. The notice under section