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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

T.C. Agro Food Industries, Haryana vs. Income Tax Officer, Ward-1, Karnal, Haryana

ITA 5719/DEL/2024[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5719/Del/2024 : Asstt. Year: 2018-19 M/S T. C. Agro Food Industries, Vs Income Tax Officer, Karnal Kaithal Road, Nissing, Ward-1, Karnal, Haryana-132024 Karnal, Haryana-132024 (Appellant) (Respondent) Pan No. Aajft1315N Assessee By : Sh. Somil Agarwal, Adv. & Ms. Shilpa Gupta, Adv. Revenue By : Ms. Amish S. Gupt, Cit-Dr

For Appellant: Sh. Somil Agarwal, Adv. &For Respondent: Ms. Amish S. Gupt, CIT-DR
Section 131(1)Section 147Section 263Section 68Section 69C

admitting him to be an entry provider all along. And that this assessee has been found as a beneficiary of his very well organized accommodation entries network; and, therefore, T. C. Agro Food Industries we ought to uphold these fictitious sales as well as bogus purchases/disallowance addition in very terms ... documentary evidence all along, the department is very well in possession the corresponding section 131(1) statement that it has been a beneficiary of accommodation entry network which has not been specifically controverted in both the lower proceedings. Coming to the Revenue’s case as well

Manish Pahwa, New Delhi vs. ITO Ward 45(2), New Delhi

The appeal is partly allowed with consequences to follow as

ITA 3270/DEL/2023[2011-12]Status: DisposedITAT Delhi09 Jan 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2011-12 Manish Pahwa, Vs Ito, J-554, Rajouri Garden, Ward-45(2), New Delhi– 110 027. Delhi. Pan: Aaapp0676M

For Appellant: Shri Nitin Gulati, AdvocateFor Respondent: Ms Ankush Kalra, Sr. DR
Section 147Section 69Section 69C

however, treated this as a bogus expenditure on the premise that Gopal I.T. International was found by the Investigation Wing to be 6 an accommodation-entry provider. The AO noted that Mr. Gopal Kumar, proprietor, did not file an ROI for AY 2011-12 and could not be found ... upheld the addition, concurring that the genuineness of the payment was not established and citing the above investigative findings treating the transaction as an accommodation entry. 5.1 Ld. AR has submitted that the disallowance is based on suspicion and third-party information, not on any cogent evidence that the assessee

Gopal Mathurdas Parikh, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

In the result, both these appeals are also partly allowed

ITA 408/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2015-16

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133(6)Section 143(3)Section 148

selling through the assessee. It is clear that money was being routed through assessee's bank account and is a classic case of accommodation entry. Therefore the assessment was reopened issuing notice u/s. 148 of the Act. 2.1. In response assessee filed his Return of Income and replied ... demanded tax thereon. 3. On appeal against the reassessment order, Ld. CIT(A) estimated the gross profit at 2% of total accommodation entries amounting to Rs.17,41,89,105/- appearing in the Nutan Nagrik Sahakari bank account and thereby partly allowed the appeal of the assessee by observing as follows

Gopal Mathurdas Parikh, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

In the result, both these appeals are also partly allowed

ITA 407/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133(6)Section 143(3)Section 148

selling through the assessee. It is clear that money was being routed through assessee's bank account and is a classic case of accommodation entry. Therefore the assessment was reopened issuing notice u/s. 148 of the Act. 2.1. In response assessee filed his Return of Income and replied ... demanded tax thereon. 3. On appeal against the reassessment order, Ld. CIT(A) estimated the gross profit at 2% of total accommodation entries amounting to Rs.17,41,89,105/- appearing in the Nutan Nagrik Sahakari bank account and thereby partly allowed the appeal of the assessee by observing as follows

Gopal Mathurdas Parikh, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

In the result, both these appeals are also partly allowed

ITA 406/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133(6)Section 143(3)Section 148

selling through the assessee. It is clear that money was being routed through assessee's bank account and is a classic case of accommodation entry. Therefore the assessment was reopened issuing notice u/s. 148 of the Act. 2.1. In response assessee filed his Return of Income and replied ... demanded tax thereon. 3. On appeal against the reassessment order, Ld. CIT(A) estimated the gross profit at 2% of total accommodation entries amounting to Rs.17,41,89,105/- appearing in the Nutan Nagrik Sahakari bank account and thereby partly allowed the appeal of the assessee by observing as follows

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

mentioned by the CIT (A) in his appellate order and also in reasons recorded in para 2 (supra) that the fact that assessee taken accommodation entry of bogus LTCG was found from the search of Evergreen Enterprises, then the only course available to the revenue was to take the route ... explored and enquired. Such enquiry revealed significant information in regard to M/s. Green Valley Gems Pvt. Ltd. which according to the Revenue had provided accommodation entries to the petitioner, in which it was also revealed that M/s. Green Valley Gems Pvt. Ltd. was a shell company. Accordingly reopening proceedings

Income Tax Officer, Ward 2(1), Thane vs. Bherulal Chunnilal Jain, Thane

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

ITA 5039/MUM/2024[2009-10]Status: DisposedITAT Mumbai08 Jan 2026AY 2009-10

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Income Tax Officer, Mr. Bherulal Chunnilal Jain, Ward 2(1), B 201, Jay Rajleela Chs Ltd., Room No.25, B Wing, Deepak Nagar, 90 Feet Road, Vs. Ashar It Park, Bhayander West, Wagle Estate, Maharashtra – 400 101 Thane – 400 604 Pan:Afnpj6760J (Appellant) : (Respondent)

For Respondent: Shri S. Srinivasu, CIT DR
Section 143(1)Section 143(3)Section 148Section 250Section 271(1)(c)Section 68

even the Ld. CIT(A) has not discussed anything on the documentary evidences furnished by the assessee pertaining to the alleged beneficiaries of such accommodation entry. The Ld. DR relied on the order of the Ld. AO. 9. We find justification in the arguments of the Ld. DR in holding ... Even before us there are no documentary evidences filed by the assessee. Mere denial on the ground that the account was used by an accommodation entry provider Shri Rajesh Pamecha without substantiating with corroborative evidences does not discharge the assessee from his liability. Though the Ld. CIT(A) has relied

Chintan Dwarkadas Chotai, Junagadh vs. DCIT/ACIT Cir 1(1), RKT, Rajkot

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

ITA 636/RJT/2025[2019-20]Status: DisposedITAT Rajkot07 Jan 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 132Section 147Section 148Section 270ASection 272A(1)(d)Section 80G

charitable trust, i.e. All India Education Charitable Trust during the assessment year 2019-20. Accordingly, the AO was concluded that the assessee had obtained accommodation entry in the form of charitable trust of Rs.1,12,482/- from All India Education Charitable Trust during the FY 2018-19 relevant

Raju Bababhai Desai, Ahmedabad vs. The ITO, Ward-3(3)(4), Ahmedabad

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

ITA 2051/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri M.K. Patel, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 144Section 153ASection 245D(4)Section 250Section 68

Conferencing which cannot took place due to technical glitches. П. Addition on account of transaction in penny stock Rs. 4,41,52,811/-and accommodation entry through Tamilnadu Mercantile Bank Ltd - Rs. 4,74,61,580/- as unexplained cash credit u/s. 68 of the Act aggerating to Rs.9 ... grievously erred in law and on facts in confirming the addition on account of transaction in Penny stock at Rs.4,41,52,811/- and accommodation entry through Tamilnadu Mercantile Bank at Rs.4,74,61,850/-i.e. both source of funds and its application as unexplained cash credit

Assisstant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. M/S Ei Instrumentation Private Limited, Chennai

In the result, appeal filed by the Revenue is dismissed

ITA 1554/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Ms.Janani, AdvocateFor Respondent: Ms.Kavitha, Addl.CIT
Section 139Section 148Section 69C

assessee and was of the view that the transaction shown by the assessee with M/s.Barbrik which is a paper entity is nothing but accommodation entry and held it to be in-genuine in the light of the investigation conducted by the Investigation Directorate, and also noted that the said company ... reopened u/s.147 of the Act based on the information from the Investigation Wing, (Kolkata) that M/s.Barbrik had indulged in providing fraudulent invoices for facilitating accommodation entry for entities [like assessee], so that beneficiary entity could suppress its profits; and since the assessee had ITA No.1554 /Chny/2025

Income Tax Officer-19(1)(1), Mumbai vs. Babulal Mishrimalji Mehta, Mumbai

In the result, the grounds of appeal raised by the revenue are

ITA 6131/MUM/2025[2019-20]Status: DisposedITAT Mumbai07 Jan 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Arun Khodpia(Physical Hearing) Income Tax Officer-19(1)(1), Babulal Mishrimalji Mehta 501, 5Th Floor, Piramal Chamber, Vs 7 Marker Building, Office No.91St Lalbaug, Mumbai Panjarapole Lane, Mumbai [Pan:Afbpm0921N] Appellant / Assessee Respondent / Revenue

Section 254(1)Section 68Section 69C

CBDT's Circular No .05/2024 Dated. 15.03.2024, wherein it is stated that in cases involving" Organized Tax Evasion" including cases of accommodation entry of bogus purchases," in such cases the decision to file appeal/SLP shall be taken on merit without regard to the tax effect and the monetary limit ... have been identified as the parties involved in fraud input tax credit, which were not engaged in any genuine business activities and merely provided accommodation entries for the purpose of booking bogus expenses for reducing taxable income. During post search investigation the key person of such entities in their statement

Asstt. Commisioner, Mumbai vs. Supreme Lake View Bungalows Private Limited, Powai, Mumbai

In the result the appeal of the revenue bearing ITA No

ITA 5735/MUM/2025[2022]Status: DisposedITAT Mumbai07 Jan 2026

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 139Section 143(1)Section 143(3)Section 250Section 36(1)(iii)Section 68

contended that summons u/s 131 remained un-complied with as perlower appellate findings under challenge and all of the assessee’s investor parties were accommodation entry providers which had been rightly treated as bogus in both the lower proceedings. In the facts of the present case, both the nature & source

Kaishar Interiors Private Limtied, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(2)(2), Mumbai

Accordingly Ground No.16 raised by the Assessee is allowed

ITA 5665/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh Kukreja &For Respondent: Shri Hemanshu Joshi
Section 143(3)Section 147Section 148Section 14A

information received from the Director General of Income Tax (Investigation), Mumbai to the effect that Assessee was one of the beneficiary of receiving bogus accommodation entry for purchase of goods from the parties identified by the Maharashtra Sales 3 Assessment Year 2010-2011 Tax Department as Hawala Operator, reassessment proceedings ... stand that out of 13 parties stated in the reasons recorded for reopening assessment from whom the Assessee was alleged to have taken bogus accommodation entry, the Assessee had only transacted with 3 parties (namely, M/s. Parasnath Enterprises, M/s. Shiv Industries & Karni Granimarmo Pvt. Ltd.) during the relevant previous year

Assistant Commissioner of Income Tax-19(3), Mumbai vs. Rajen Kirtilal Shah, Mumbai

Accordingly, all the grounds raised by the Revenue are dismissed

ITA 5438/MUM/2025[2013-14]Status: DisposedITAT Mumbai07 Jan 2026AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dharmil JhaveriFor Respondent: Shri Annavaran Kosuri
Section 144Section 144BSection 147Section 68

facts that during the course of investigation, a was found that the scrips in which the assessee traded is penny stock used for providing accommodation entry only in form of bogus LTCG and shared with the jurisdictional AO. 7. Whether on the facts and circumstances of the ease ... accounts. During the course of post search investigation of Akshar Group of Vadodara, it was seen that one of the partners had taken accommodation entry in the form of Long Term Capital Gain in the scrip of Bakra pratisthan Ltd. listed on Calcutta Stock Exchange. Unaccounted money of the beneficiaries

Ashish Girish Jain, Mumbai vs. ITO, Ward 42(1)(1), Mumbai

ITA 5328/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh ShahFor Respondent: Shri Pradipsinh Saktavat
Section 132Section 143(1)Section 143(3)Section 147Section 148

recorded as well as detailed enquiries made by the Investigation Wing. It was revealed that Rajendra Jain Group and Dharmichand Jain Group were providing accommodation entries like bogus purchase, sales, unsecured loans, share capital etc. Further, from the details received from the DGIT (Inv.), Mumbai it is seen that ... Assessee, was one of the beneficiary who obtained accommodation entries of INR.15,00,000/- under the garb of ‘Unsecured Loan’, during the Financial Year 2009-2010 relevant to the Assessment Year 2010- 2011 from Mani Prabha Impex Pvt. Ltd., one of the group concerns of Dharmichand Jain Group. Accordingly

Passion Realtech Private Limited, Gurgaon vs. ACIT, Central Circle-2, Faridabad

In the result appeal of the assessee is partly allowed

ITA 1248/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 250Section 68

upholding the addition made by the Ld. AO u/s 68 on account of treating M/s. Height Propcon Put. Ltd. as adummy entity Le. accommodation entry provider and placed reliance on the statement of alleged person who was not even the director of the impugned company. That on the facts ... Propcon Put. Ltd. and disproved the identity of said company and adjudged legitimate business transaction as a non- genuine transaction and treated as an accommodation entry. That on the facts and in the circumstances of the case, the Ld. CIT- (A) has erred in treating the appellant company

Bholenath Foods Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle- 4(2), New Delhi

The appeal of the assessee is disposed of in above terms

ITA 5777/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Jan 2026AY 2012-13

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwalassessment Year : 2012-13 Bholenath Foods Limited, Vs. Income Tax Officer, Shop No.208, Ward 47(1), Bldg. No.2612/13, Naya Bazar, New Delhi. Delhi – 110 006. Pan: Aabcb3842P

For Appellant: Shri Shivam Yadav, Advocate &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 250Section 68

referred to as ‘the Act’) wherein the Addition of Rs.1,35,19,962/- made by the AO allegedly on account of bogus purchase and accommodation entries was confirmed and the appeal of the assessee was dismissed. 2. The facts in brief as culled out from the proceedings of the authorities ... recorded. During the search proceedings, Shri Ram Prakash Bhatia accepted in his statement recorded on oath that he was in the business of providing accommodation entries for the purpose of which he has floated various proprietorship concerns. In his statement, he has confirmed that Jai Bharat Foods

Income Tax Officer(E) Ward- 2(4), New Delhi, Civic Centre New Delhi vs. Prakash Sewa Trust, Paschim Vihar

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 12ASection 143(3)

such funds under the guise of donation, such donation, found to be devoid of charitable substance and routed to an entity engaged in accommodation entries, constitutes a clear case of misapplication of income. Hence in nutshell it is seen that this is a classic case of misuse of the exemption ... trust sold its trust property during the year under consideration and donated the sale proceeds to another charitable trust which was controlled by the accommodation entry providers; (iii) the property sold was an agricultural land, however, no agricultural income was offered by the appellant trust for the use of such

Bijoy Kumar Agarwal, Ranchi vs. ACIT/DCIT Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 310/RAN/2025[11-12]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri Sonjoy Sarmaandshri Ratnesh Nandan Sahay, Accountantmember

Section 133(6)Section 143(2)Section 147Section 148Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL BENCH-RANCHI VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member andShri Ratnesh

Naveen Singh, Jamshedpur vs. Deputy Commissioner of Income Tax, Circle - 1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

wherein it has been held as under: “where reassessment was resorted to on basis of information from DIT (Investigation) that assessee had received accommodation entry but and there was no independent application of mind by Assessing Officer to tangible material and reasons failed to demonstrate link between tangible material