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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

Globus Housing, Bhopal vs. Assessment Unit, NFAC, Delhi

The appeal of the assessee is allowed and the “impugned

ITA 872/IND/2024[2014-15]Status: DisposedITAT Indore10 Oct 2025AY 2014-15

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 142(1)Section 147Section 148Section 250Section 253Section 68

possession of certain credible information as per which the assessee had received unexplained credits amounting to Rs. 87,00,000/- in the form of accommodation entry from M/s Jyoti India Pvt. Page 2 of 15 Globus Housing ITA. No.872/Ind/2024 – A.Y. 2014-15 Ltd during the financial year ... bank accounts of Shri Sharad Darak, Indore about abnormal financial transactions. As per the information received, it was found that the assessee had received accommodation entry from Shri Sharad Darak. It was noticed from the statement of Shri Krishan Murari Naita wherein he had made the categorical admission that

Pramila Agarwal, Jaipur vs. The Income Tax Officer Ward-2(5), Jaipur

In the result, the appeal of the assessee is allowed

ITA 531/JPR/2025[2011-12]Status: DisposedITAT Jaipur10 Oct 2025AY 2011-12
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 10(38)Section 147Section 148Section 68

deleted. 5. That the Ld. CIT(A) further erred in upholding assumption of the ld. AO that payment of commission on the alleged accommodation entry, presumed to have taken by the assessee, and made an addition of Rs. 8,51,610/- by assuming this fictitious commission payment ... various places and during the searches and as per the information made public by the SEBI, it was discovered that various syndicates have arranged accommodation entry of bogus LTCG, Bogus STCG / Bogus Long / Short Term Capital Loss through trading of shares of Penny Stocks. Further on the basis of information

Sana Md.Saqib Puthawala, Ahmedabad vs. The ITO, Ward-1(1)(1), Ahmedabad

In the result, the appeal of the Assessee is allowed

ITA 624/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 10(38)Section 147Section 148Section 148ASection 250Section 69C

basis of information uploaded on Insight portal that a search action was conducted in the case of M/s. Kushal Group which revealed that bogus accommodation entries were provided in the form of Long Term Capital Gain/Short Term Capital Gain and the assessee was one of the beneficiaries. Accordingly, a notice ... also requested the A.O. to provide the details, statements, reports available with the A.O. in support of the contention that the assessee had obtained accommodation entry in respect of these transactions. However, no material or evidence was provided to the assessee and thus the addition was based on mere presumption

Mohammedsaqib Aiyub Puthawala, Ahmedabad vs. The PCIT-1, Ahmedabad

In the result, the appeal of the Assessee is allowed

ITA 623/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 10(38)Section 147Section 263

Subsequently, the case record was called for examined by the Ld. PCIT who found that since no addition was made in respect of bogus accommodation entry of Rs.12,18,543/- in the form of exempt LTCG, the order of the A.O. was erroneous and prejudicial to the interest of revenue ... account of the assessee. Further, that there was no material available with the A.O. to treat the transaction of the assessee as accommodation entry and the A.O. had given a specific finding in this regard in the assessment order. Therefore, the Ld. PCIT was not correct in revising the order

Ashok Amarnath Agrawal, Vadodara vs. The Dy.CIT, Circle-2(1)(1), Vadodara

In the result, appeal of the assessee in ITA No

ITA 1078/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri B.P. Srivastava, Sr DR
Section 10(38)Section 132Section 147Section 250Section 271ASection 68

Assessing Officer reopened the case on the allegation that the assessee had earned fictitious LTCG of Rs.10,94,043/- from Kushal Limited, an alleged accommodation entry provider. The Assessing Officer disallowed the claim and treated the entire sale proceeds of Rs.23,81,100/- as unexplained cash credits under section ... noticed that during F.Y 2017-18 the assessee is beneficiary an amount of Rs.10,94,043/- on account of fictitious capital gain through accommodation entry provided by Kushal Limited. On further analysis of the same, it is found that there is systematic record of receipt of the various transactions

Ashok Amarnath Agrawal, Vadodara vs. The Dy.CIT, Circle-2(1)(1), Vadodara

In the result, appeal of the assessee in ITA No

ITA 1077/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri B.P. Srivastava, Sr DR
Section 10(38)Section 132Section 147Section 250Section 271ASection 68

Assessing Officer reopened the case on the allegation that the assessee had earned fictitious LTCG of Rs.10,94,043/- from Kushal Limited, an alleged accommodation entry provider. The Assessing Officer disallowed the claim and treated the entire sale proceeds of Rs.23,81,100/- as unexplained cash credits under section ... noticed that during F.Y 2017-18 the assessee is beneficiary an amount of Rs.10,94,043/- on account of fictitious capital gain through accommodation entry provided by Kushal Limited. On further analysis of the same, it is found that there is systematic record of receipt of the various transactions

DCIT, Central Circle - 4(4), Kolkata vs. M/S. Evernewcommodeal Pvt. Ltd., Kolkata

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1536/KOL/2025[2019-20]Status: DisposedITAT Kolkata10 Oct 2025AY 2019-20

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

petitioner is that the Assessing Officer had attempted to fill in the gap by terming the amount received from Basant Marketing Pvt. Ltd. as "accommodation entry", which she could not have done without further inquiry/verification. Yet another contention emphasized by the learned Senior Counsel is that the post notice correspondence ... urged that in absence of any statement given by any Director of Basant Marketing Pvt. Ltd. stating that the assessee received and obtained accommodation entry in the form of loans and advances, the reasons lack basis. The Director Mr. Dalmia of Basant Marketing Pvt. Ltd. as contended also does

DCIT, Central Circle - 4(4), Kolkata vs. M/S. Evernewcommodeal Pvt. Ltd., Kolkata

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1535/KOL/2025[2018-19]Status: DisposedITAT Kolkata10 Oct 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

petitioner is that the Assessing Officer had attempted to fill in the gap by terming the amount received from Basant Marketing Pvt. Ltd. as "accommodation entry", which she could not have done without further inquiry/verification. Yet another contention emphasized by the learned Senior Counsel is that the post notice correspondence ... urged that in absence of any statement given by any Director of Basant Marketing Pvt. Ltd. stating that the assessee received and obtained accommodation entry in the form of loans and advances, the reasons lack basis. The Director Mr. Dalmia of Basant Marketing Pvt. Ltd. as contended also does

Hi-Tech Engineers, Mumbai vs. Central Circle 5(1), Bandra Mumbai

ITA 3166/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Oct 2025AY 2019-20

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Bhavik ChhedaFor Respondent: Shri Ritesh Misra
Section 153ASection 270ASection 270A(2)Section 270A(2)(a)Section 270A(9)(a)Section 270A(9)(f)Section 69C

presumption drawn is that the assessee might have procured the material [for execution of work] from the grey market and have approached these accommodation entry providers-(seven parties) for accommodation bills by giving commission to them, for saving some money. Therefore, the gross profit (GP) only need to be added

Hi-Tech Engineers, Mumbai vs. Central Circle 5(1), Bandra East, Mumbai

ITA 3165/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Bhavik ChhedaFor Respondent: Shri Ritesh Misra
Section 153ASection 270ASection 270A(2)Section 270A(2)(a)Section 270A(9)(a)Section 270A(9)(f)Section 69C

presumption drawn is that the assessee might have procured the material [for execution of work] from the grey market and have approached these accommodation entry providers-(seven parties) for accommodation bills by giving commission to them, for saving some money. Therefore, the gross profit (GP) only need to be added

ACIT Central Circle 7 (1 ), Mumbai vs. Shrilekha Trading Private Limited, Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 3092/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Snehal ShahFor Respondent: Shri Vivek Perampura (CIT-DR)
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

ACIT Central Circle 7 (1), Mumbai vs. Shrilekha Trading Private Limited, Mumbai

ITA 3049/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Oct 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

ACIT Central Circle 7 (1), Mumbai vs. Shrilekha Trading Private Limited, Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 3048/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Snehal ShahFor Respondent: Shri Vivek Perampura (CIT-DR)
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

ACIT Central Circle 7 (1), Mumbai vs. Shrilekha Trading Private Limited, Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 3047/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Snehal ShahFor Respondent: Shri Vivek Perampura (CIT-DR)
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

ACIT Central Circle 7 1, Mumbai vs. Shrilekha Trading Private Limited, Mumbai

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

ITA 3046/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

ACIT Central Circle 7(1), Mumbai vs. Shrilekha Trading Private Limited, Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 3045/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Snehal ShahFor Respondent: Shri Vivek Perampura (CIT-DR)
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

ACIT Central Circle 7 1, Mumbai vs. Shrilekha Trading Private Limited, Mumbai

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

ITA 3044/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

Shrilekha Trading Private Limited, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2750/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Oct 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Snehal ShahFor Respondent: Shri Vivek Perampura (CIT-DR)
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

Shrilekha Trading Private Limited, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2749/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Snehal ShahFor Respondent: Shri Vivek Perampura (CIT-DR)
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding

Shrilekha Trading Private Limited, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the revenue are dismissed

ITA 2748/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Snehal ShahFor Respondent: Shri Vivek Perampura (CIT-DR)
Section 132Section 143(3)Section 145Section 153ASection 250

assessee has taken loan from bank and the assessee is running the business which is not genuine. The Ld.AO found that assessee is accommodation entry provider, involved in bogus purchases and bogus sales without back by any genuine delivery of goods and services. The Ld.AO rejected the books of account ... question was asked by the searched parties or the authorised officers that any such person or entity have given any kind of accommodation entry to the assessee or the loan given by these parties were bogus. The entire allegation of the AO based on the statement recorded and finding