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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

Shah Mahendrakumar Mafatlal (HUF), Mithkhali vs. Income Tax Officer, Ward 1(1)(3), Ahmedabad

In the result, the appeal of the assessee for A

ITA 1689/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad06 Jan 2026AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1688 & 1689/Ahd/2025 (िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16) बनाम/ Shah Mahendrakumar Income Tax Officer Mafatlal Huf Ward-1(1)(3), Vs. 27D, Maharashtra Society, Ahmedabad Anmol Mithkhali Owners Asso Mithkhali, Ellisbridge, Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaihs8263H (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Sulabh Padshah, Ar ""यथ" क" ओर से/Respondent By : Shri Yogesh Mishra, Sr. Dr 16/12/2025 Date Of Hearing Date Of Pronouncement 06/01/2026

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147

basis of information received from the Investigation Wing reflected on Insight Portal of the Department that the assessee had taken accommodation entry of Rs.47,41,600/- during the year in the form of fictitious loan from one Shri Jignesh Shah. In the course of assessment, the assessee had denied having ... however, did not accept the explanation of the assessee and the alleged loan of Rs.47,41,600/- taken from Shri Jignesh Shah was held accommodation entry and added to the income. The assessment was completed u/s.147 r.w.s. 144B of the Act on 30.03.2022 at total income of Rs.61

Shah Mahendrakumar Mafatlal (HUF), Mithkhali vs. Income Tax Officer, Ward 1(1)(3), Ahmedabad

In the result, the appeal of the assessee for A

ITA 1688/AHD/2025[ 2014-15]Status: DisposedITAT Ahmedabad06 Jan 2026

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1688 & 1689/Ahd/2025 (िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16) बनाम/ Shah Mahendrakumar Income Tax Officer Mafatlal Huf Ward-1(1)(3), Vs. 27D, Maharashtra Society, Ahmedabad Anmol Mithkhali Owners Asso Mithkhali, Ellisbridge, Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaihs8263H (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Sulabh Padshah, Ar ""यथ" क" ओर से/Respondent By : Shri Yogesh Mishra, Sr. Dr 16/12/2025 Date Of Hearing Date Of Pronouncement 06/01/2026

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147

basis of information received from the Investigation Wing reflected on Insight Portal of the Department that the assessee had taken accommodation entry of Rs.47,41,600/- during the year in the form of fictitious loan from one Shri Jignesh Shah. In the course of assessment, the assessee had denied having ... however, did not accept the explanation of the assessee and the alleged loan of Rs.47,41,600/- taken from Shri Jignesh Shah was held accommodation entry and added to the income. The assessment was completed u/s.147 r.w.s. 144B of the Act on 30.03.2022 at total income of Rs.61

S Chandra Prakash, Chennai vs. ITO, Central Circle-3(2), Chennai

ITA 2815/CHNY/2025[2021-22]Status: DisposedITAT Chennai05 Jan 2026AY 2021-22

Bench: Shri Aby T Varkey & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:2815/Chny/2025 & Sa No.105/Chny/2025 निर्धारण वर्ष / Assessment Year: 2021-22 S.Chandra Prakash, No.13/5, Vritti Apartment, 2A, Ormes Road, 3Rd Cross Street, Kilpauk S.O, Kilpauk, Chennai – 600 010. Ito, Vs. Central Circle – 3(2), Chennai. [Pan: Aaapc-4541-Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Mr. Y. Sridhar, F.C.A. प्रत्यर्थी की ओर से/Respondent By : Ms. R. Anitha, Addl. Cit. सुनवाई की तारीख/Date Of Hearing : 04.12.2025 घोषणा की तारीख/Date Of Pronouncement : 05.01.2026 आदेश /Order Per S. R. Raghunatha, Ам: This Appeal & Stay Application Filed By The Assessee Is Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Chennai - 20 (In Short "Cit(A)") Passed U/S.250 Of The Income-Tax Act, 1961 (In Short "The Act") Dated 08.08.2025 Pertaining To Assessment Year (Ay) 2021-22 Against The Order Passed By The Acit, Central Circle-3(2), Chennai, U/S.143(3) Of The Act Dated 30.12.2022. :-2-:

For Appellant: Mr. Y. Sridhar, F.C.AFor Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 132ASection 143(3)Section 250Section 69

paper book submitted before the AO and that of the Id.CIT(A) had proved this point and hence, it cannot be an accommodation entry as alleged by the revenue. 60. It was further stated that when the letter was provided on 30.03.2021, nothing prevented the ADIT(Inv.) and the ACIT

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Bans Aerosol Private Limited, Delhi

Appeal of the Revenue is dismissed being devoid of any merit

ITA 7127/DEL/2025[2018-19]Status: DisposedITAT Delhi02 Jan 2026AY 2018-19

Bench: Shri Vikas Awasthyआअसं.7127/धिल्ली/2025 (नि.व. 2018-19) Assistant Commissioner Of Income Tax, Central Circle-25, R.No 317, 3Rd Floor, Ara Centre, ...... अपीलार्थी/Appellant Jhandewalan Extn. Delhi 110055 बिाम Vs. Bans Aerosol P. Ltd., 3/110, Lalita Park, Laxmi Nagar, Delhi 110092 ..... प्रनिवादी/Respondent Pan: Aaccb-1901-C अपीलार्थी द्वारा/Appellant By : Shri Manoj Kumar, Sr. Dr प्रधििािीद्वारा/Respondent By : Shri Akash Ojha, Advocate (Through Vc) सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 02/01/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-29, Delhi [In Short ‘The Cit(A)’] Dated 07.07.2025, For Assessment Year 2018-19. 2. The Appeal Is Time Barred By 7 Days. The Revenue Has Filed An Application Citing Reasons For Delay In Filing Of Appeal. After Perusal Of Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, The Delay Has Been Caused For The Reasons Stated In Application Which Appears To Be Bonafide. Considering The Explanation Furnished By The Department, Delay Of 7 Days In Filing Of Appeal Is Condoned & Appeal Is Taken Up For Adjudication On Merits.

For Appellant: Shri Manoj Kumar, Sr. DRFor Respondent: Shri Akash Ojha, Advocate (Through VC)
Section 133(6)Section 144BSection 147Section 148ASection 68Section 69C

assessee. 4. Shri Manoj Kumar, representing the department vehemently defending the Assessment Order submitted that the Investigation Wing had unearthed a well- organized accommodation entry racket. M/s Sirsa Deposits and Advances Pvt. Ltd. 3 is one such shell entity lacking creditworthiness and engaged in providing bogus entries. Therefore, the additions ... assessee held that the loan taken by the assessee from M/s Sirsa Deposits and Advances Pvt. Ltd. is non genuine and is merely an accommodation entry. The CIT(A) after examining the aforesaid document concluded that the loan transaction was genuine and the assessee has discharged his onus in establishing