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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

Palmon Impex Pvt Ltd, Mumbai vs. Income Tax Officer- 7(3)(1), Mumbai

In the result, both the appeals filed by the assessee and revenue are

ITA 2561/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Jul 2025AY 2011-12

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

regular scrutiny u/s 143(3) of the Act. Subsequently, based on the information that, during the FY 2010-11, the assessee had availed accommodation entries in the form of bogus purchases from three concerns i.e. (i) M/s. Monica InternationalRs.18,21,402/-, (ii) M/s. Arihant Trading Co.- Rs.11 ... prove the purchases on which claim for deduction was made before the AO and in the instant case, since the purchases are recorded by accommodation entry in the books of account and sales have not been disputed and the Ld. CIT(A) was not justified in estimating the profit, when

Jeet Kaur, Sainik Farm vs. Income Tax Officer Ward 19(3), Delhi

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 5512/DEL/2024[2013-14]Status: DisposedITAT Delhi28 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

Section 143(1)Section 148Section 148ASection 69

Thereafter, reassessment proceedings were initiated vide notice under section 148 of the Act on the reasoning that the assessee had taken accommodation entry of Rs.59,24,700/- through penny stock of Presha Metallurgical Ltd. The Assessing Officer (‘AO’) had given many opportunities to the assessee for explaining the genuineness

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

Rs.1,42,694/- as against huge turnover of Rs.24,10,82,501/- and had not shown any income from commission received on providing accommodation entries and there was detailed investigation by the Income Tax Department, which substantiated the case of the department. It was thus held that formation of belief ... been held as under: Reassessment – Notice – Condition precedent – Formation of belief that income escaped assessment Assessing Officer treating share application money as bogus accommodation entries Payments through banking channel and companies investing money genuine No independent application of mind by Assessing Officer but acting under information from investigation wing - Notice

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

Rs.1,42,694/- as against huge turnover of Rs.24,10,82,501/- and had not shown any income from commission received on providing accommodation entries and there was detailed investigation by the Income Tax Department, which substantiated the case of the department. It was thus held that formation of belief ... been held as under: Reassessment – Notice – Condition precedent – Formation of belief that income escaped assessment Assessing Officer treating share application money as bogus accommodation entries Payments through banking channel and companies investing money genuine No independent application of mind by Assessing Officer but acting under information from investigation wing - Notice

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

Rs.1,42,694/- as against huge turnover of Rs.24,10,82,501/- and had not shown any income from commission received on providing accommodation entries and there was detailed investigation by the Income Tax Department, which substantiated the case of the department. It was thus held that formation of belief ... been held as under: Reassessment – Notice – Condition precedent – Formation of belief that income escaped assessment – Assessing Officer treating share application money as bogus accommodation entries Payments through banking channel and companies investing money genuine No independent application of mind by Assessing Officer but acting under information from investigation wing - Notice

Ravinder Singh Thakkar, Jaipur vs. Assistant Commssioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

Rs.1,42,694/- as against huge turnover of Rs.24,10,82,501/- and had not shown any income from commission received on providing accommodation entries and there was detailed investigation by the Income Tax Department, which substantiated the case of the department. It was thus held that formation of belief ... been held as under: Reassessment – Notice – Condition precedent – Formation of belief that income escaped assessment Assessing Officer treating share application money as bogus accommodation entries Payments through banking channel and companies investing money genuine No independent application of mind by Assessing Officer but acting under information from investigation wing - Notice

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

Rs.1,42,694/- as against huge turnover of Rs.24,10,82,501/- and had not shown any income from commission received on providing accommodation entries and there was detailed investigation by the Income Tax Department, which substantiated the case of the department. It was thus held that formation of belief ... been held as under: Reassessment – Notice – Condition precedent – Formation of belief that income escaped assessment Assessing Officer treating share application money as bogus accommodation entries Payments through banking channel and companies investing money genuine No independent application of mind by Assessing Officer but acting under information from investigation wing - Notice

Gupta Ashok Kumar, Hyderabad vs. Income Tax Officer, Ward-1(2), Hyderabad

In the result, appeal of the assessee allowed

ITA 376/HYD/2024[2014-15]Status: DisposedITAT Hyderabad25 Jul 2025AY 2014-15

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, P Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 148Section 68

statement from Sri Mukesh Banka was recorded under section 132(4) of the Act on 19.07.2018, where he has admitted to have provided accommodation entries of unsecured loans/share capital and share premium to various persons and earned commission. The Assessing Officer further noticed that, Mr. Mukesh Banka furnished a list ... statement recorded from Mr. Mukesh Banka under section 132(4) of the Act dated 19.07.2018 observed that, the assessee is a beneficiary of accommodation entries provided 7 ITA.No.376/Hyd./2024 by entry provider through shell/paper companies, which is evident from the modus operandi employed by Mr. Mukesh Banka, where

Deputy Commissioner of Income Tax, Central Circle-2(3), Kolkata, Aayakar Bhawan Poorva vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 276/KOL/2025[2021-22]Status: DisposedITAT Kolkata25 Jul 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Dailmer Industries Private Tax, Central Circle-2(3), Limited 4Th Floor, Room No. 403, 67/C, Balaram Dey Street, Vs. Kolkata-700107, West Bengal Kolkata-700006, West Bengal (Appellant) (Respondent) Pan No. Aabcd0836D Assessee By : S/Shri Soumitra Choudhury & Nirav Sheth, Ars Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 20.05.2025 Date Of Pronouncement: 25.07.2025

For Appellant: S/Shri Soumitra Choudhury &For Respondent: Shri Raja Sengupta, DR
Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 68

issued to the appellant company with respect to the aforesaid statement of Navin Kumar Saffar. There is allegation that the said loan represent accommodation entry transaction. It was submitted by the appellant company that the said data file contains the list of loan transactions (and not a alleged accommodation entry ... commission is being received by the finance broker from the lender. Thus, it was submitted that the transaction represent actual loan transaction and not accommodation entry. With respect to cash commission mentioned in the excel sheet.He had also stated that there is some kick back of such commission income earned

Trenchless Engineering Sevices Pvt Ltd, Delhi vs. DCIT, Central Circle-06, Delhi

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

ITA 143/DEL/2025[2015-16]Status: DisposedITAT Delhi25 Jul 2025AY 2015-16

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

Section 132Section 139Section 143(3)Section 153Section 153CSection 68Section 69Section 69C

carried out in the Ashish Begwani Group of cases, Sh. Ashish Begwani was found to be involved in facilitation of accommodation entry along with the Kolkata based entry providers Sh. Gopal Kumar Aggarwal and his son Sh. Vikas Kumar Aggarwal. During the search operation various documents related to accommodation entry ... statements of Sh. Gopal Kumar Aggarwal and his son Vikas Kumar Aggarwal it was found that the assessee is a beneficiary who had taken accommodation entry from entities controlled by Sh. Ashish Begwani and others. The assessee filed its original return of income

DCIT, New Delhi vs. M/S Gen X Commodities (P) Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 3560/DEL/2016[2010-11]Status: DisposedITAT Delhi25 Jul 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Amitabh Shukla[Assessment Year : 2010-11] Dcit Vs M/S. Gen X Commodities (P) Ltd., Central Circle-29 Fa-45, Shivaji Enclave New Delhi New Delhi-110027 Pan-Aaaca2303H Appellant Respondent Shri Jitender Singh, Cit Dr Revenue By Assessee By Shri Ved Jain, Adv. & Shri Ayush Garg, Ca Date Of Hearing 26.06.2025 Date Of Pronouncement 25.07.2025

Section 14ASection 2(22)(e)Section 250(6)

addition of Rs.11,97,21,030/- on account of CCM and also made further addition of Rs.92,016/- being commission earned for providing accommodation entry to the persons out of the Group. We find the Ld. CIT(A) deleted the addition, the reasons of which have already been reproduced ... order of the Ld. CIT(A) in deleting the addition made on account of Client Code Modification and commission earned for such accommodation entry. Grounds of Appeal Numbers. (a), (b) and (c) are accordingly dismissed.” 11. The issue is thus squarely covered and no longer res integra. In view

Income Tax Officer, Sikar vs. Bhaskar Chauhan, Jaipur

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a
Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

treating it regular sale transaction ignoring the fact that this sum is nothing but unaccounted income of the assessee received by him as accommodation entries? 2 . On the facts and circumstances of the case and in law the ld. CIT(A) has erred in deleting the addition of Rs.3 ... Income tax Act, 1961 on account of commission paid for acquiring accommodation entry? 3. On the facts and circumstances of the case and in law, the Id.CIT(A) is not justified in holding that to the extent of sales reported in ITR, the credit entries in the Axis bank account

Bhaskar Chouhan, Jaipur vs. Income Tax Officer, Sikar

ITA 533/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18
For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR
Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

treating it regular sale transaction ignoring the fact that this sum is nothing but unaccounted income of the assessee received by him as accommodation entries? 2. On the facts and circumstances of the case and in law the Id. CIT(A) has erred in deleting the addition of Rs.3 ... Income tax Act, 1961 on account of commission paid for acquiring accommodation entry? 3. On the facts and circumstances of the case and in law, the Id.CIT(A) is not justified in holding that to the extent of sales reported in ITR, the credit entries in the Axis bank account

Shri Salasar Balaji Developers Pvt Ltd, Jaipur vs. Income Tax Officer Ward 2(2) Jaipur, Jaipur

In the result, relevant grounds mentioned above are also allowed in toto

ITA 1188/JPR/2024[2016-2017]Status: DisposedITAT Jaipur24 Jul 2025AY 2016-2017

Bench: Shri Gagan Goyal & Shri Narinder Kumarshri Salasar Balaji Developers Private Limited, A-13-14, Shyam Nagar, Benar Road, Nadi Ka Phatak, Jhotwara, Jaipur 302012 Pan No. Aaics 7960C ...... Appellant Vs.

For Appellant: Mr. P. C. Parwal, C.A., Ld. ARFor Respondent: Mr. Manoj Kumar, JCIT, Ld. DR
Section 132Section 148Section 250Section 68Section 69C

Income Tax (Appeals) grossly erred in confirming addition of Rs. 13, 25, 35,000/- u/s. 68 of the Act on account of alleged accommodation entries received by the assessee appellant. 4.1. That on the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income ... tantamount to double addition, i.e., duly disclosed by the assessee appellant as sales of land/plots and also added by the ld. Assessing Officer as accommodation entries. 5. That on the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income Tax (Appeals) grossly erred

Omprakash Daruka, Raniganj vs. ITO, Ward 3(1), Asansol

In the result, appeal of the assessee is allowed

ITA 685/KOL/2025[2013-2014]Status: DisposedITAT Kolkata24 Jul 2025AY 2013-2014

Bench: Shri George Mathanआयकर अपील सं/Ita No.685/Kol/2025 (नििाारण वर्ा / Assessment Year :2013-2014) Omprakash Daruka, Vs Ito, Ward-3(1), Asansol C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street Kolkata-700001 Pan No. : Acqpd 1122 L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Somnath Ghosh, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 24/07/2025 घोषणा की तारीख/Date Of Pronouncement : 24/07/2025 आदेश / O R D E R

For Respondent: Shri Shankar Naskar, Sr. DR
Section 147Section 148Section 148(2)Section 149Section 151

above reopening was done after the ld. AO received information from the DIT (Investigation) Kolkata that assessee is beneficiary of accommodation entries in the form Long Term Capital Gain. The reasons recorded are available at page no. 42 of the paper book, which has been challenged by the assessee ... Investigation), Kolkata on various hsare brokers during which the share brokers have accepted their role in the entire scheme of providing accommodation entries of bogus LTCG/STCG in case of penny stock "BSR Finance & Construction Limited." (iii) From the in-depth analysis of the return filed by the assessee

Govind Corporation, Mumbai vs. DCIT Central Circle 8(1), Mumbai

In the result the appeal filed by the assessee stands

ITA 3229/MUM/2025[2014-15]Status: HeardITAT Mumbai24 Jul 2025AY 2014-15

Bench: Hon’Ble Shri Sandeep Gosain

Section 10(38)Section 115BSection 143(3)Section 250Section 68

there may not be any direct evidence in the hands of the Revenue to establish that the investment made in such companies was an accommodation entry. Thus the Court should take the aspect of human probabilities into consideration that no prudent investor would invest in peппу scrips. Considering the fact ... basis of cogent material, does not justify his conclusion that the transaction is bogus, sham and nothing other than a racket of accommodation entries. We do notice that the AO made an attempt to delve into the question of infusion of Respondent's unaccounted money

Assisstant Commissioner of Income Tax, Cir, 20(1), Mumbai vs. Anil Monshi Shah, Mumbai

In the result, ground of

ITA 2094/MUM/2025[2009-10]Status: DisposedITAT Mumbai24 Jul 2025AY 2009-10

Bench: Shri Pawan Singh& Shri Ms. Padmavathy S(Physical Hearing) Acit, Circle – 20(1), Mumbai Anil Monshi Shah 3Rd Floor, Piramal Chambers, Vs 103, Sukh Castle, Bhandarkar Road, Lalbaug, Parel, Matunga East, Mumbai – 400019. Mumbai – 400012. [Pan: Aacps9726P] Appellant / Revenue Respondent / Assessee

Section 148Section 254(1)

ignoring the fact that the Maharashtra Sales Tax Department has proved beyond doubt that the parties declared as hawala traders were involved in providing accommodation entry of purchases and the assessee was one of the beneficiary of accepting accommodation entry for the purchases. 2. Whether on the facts

ACIT-24(1), Mumbai vs. Ramesh Kumar Jain, Mumbai

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

ITA 192/MUM/2025[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2019-20 Acit-24(1), Ramesh Kumar Jain, 601, 6Th Floor, B-502, Oberoi Skyheight, Piramal Chambers, Vs. Cross Road Lokhandwala, Lalbaugh, Parel, Andheri (W), Mumbai-400012. Mumbai-400053. Pan : Adipj4196P (Appellant) (Respondent) For Assessee : Shri Rushabh Mehta For Revenue : Shri Uma Shankar Prasad, Cit-Dr Date Of Hearing : 11-06-2025 Date Of Pronouncement : 24-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Ld. Commissioner Of Income Tax(Appeals)-48, Mumbai [„Ld.Cit(A)‟], Dated 29-11-2024, Pertaining To Assessment Year (Ay) 2019-20, Wherein The Revenue Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Uma Shankar Prasad, CIT-DR
Section 131Section 133(6)Section 147Section 68Section 69C

addition of Rs.80,00,000/- on account of unexplained cash credit under section 68 of the Income Tax Act 1961 received from an accommodation entry provider." 2. "Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting ... following the same, it was held that M/s. Aneri Fincap Ltd. is not an accommodation entry provider and loan taken by the assessee company is genuine in nature. The Ld.CIT(A) further referred to the documentation submitted by the assessee in the form of copy of ITR, 3 bank statement

Income Tax Officer-42(2)(3), Kautilya Bhavan, Bkc vs. Kaushik Balubhai Madhwani, Girgaon, Mumbai

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

ITA 2861/MUM/2023[2014-15]Status: DisposedITAT Mumbai24 Jul 2025AY 2014-15

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Shri Sharwan Kumar Jha, AdvFor Respondent: Shri RiteshMisra, CIT DR
Section 10(38)Section 132(4)Section 143(3)Section 68

fact that the addition was made on account of undisclosed income on the basis of the statement recorded u/s. 132(4) of the accommodation entry provider, which is evidence as per section 132(4) of the Income Tax Act? 4. Whether on the facts and the circumstances of the case ... made u/s.68 by the ld. Assessing Officer. The addition of commission made by the ld. Assessing Officer is in respect of arrangement of accommodation entries made by the assessee towards long term capital gain. The order of ld. CIT(A) in no way deals with the said issue

Income Tax Officer, Ward-6(1)(1), Ahmedabad vs. Nimit Agarwal, Ahmedabad

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

ITA 1410/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad23 Jul 2025AY 2013-14

Bench: Smt Annapurna Gupta & Shri T.R Senthil Kumar

For Appellant: Shri Yogesh Mishra, Sr.DRFor Respondent: Ms. Astha Maniar, AR
Section 115BSection 132Section 147Section 148Section 68Section 69A

Sanjay Tibrewal) that various entities not carrying out any genuine business activity but run, controlled and managed by him are engaged in providing accommodation entries to various beneficiaries. Thus, accommodation entries amounting to Rs.3,62,60,000/- were made to the assessee. Hence, the assessment was re-opened by issuing ... been made by the AO u/s.68 of the IT Act. The AO has alleged that the appellant was beneficiary of accommodation entry from Shri Sanjay Tibrewal as he was involved in providing accommodation entries through various entities controlled and managed by Shri Sanjay Tibrewal. The AO has also relied upon