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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

DCIT, Central Circle-18, New Delhi vs. Geeta Sharma, Ghaziabad

ITA 726/DEL/2019[2011-12]Status: DisposedITAT Delhi30 Jun 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Sh. Vinay Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdqps4406L (Appellant) (Respondent) With C.O. No.60/Del/2019 [Arising Out Of Ita No.712/Del/2019] Assessment Year: 2011-12 Vs. Dcit, Sh. Vinay Sharma, B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdqps4406L (Appellant) (Respondent) With Ita Nos.716 & 717/Del/2019 Assessment Years: 2011-12 & 2012-13 Vs. Sh. Dheer Chand Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdlps0502C (Appellant) (Respondent) With C.O. Nos.64 & 65/Del/2019 [Arising Out Of Ita Nos.716 & 717/Del/2019] Assessment Years: 2011-12 & 2012-13 Vs. Dcit, Sh. Dheer Chand Sharma B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdlps0502C (Appellant) (Respondent)

Section 144Section 153ASection 37(1)

Rs.3,87,142/-; respectively as against the CIT(A)’s lower appellate discussion directing him to restrict the same @ 2.5% thereof since representing accommodation entries provided to M/s. NKG Infrastructure Limited in the form of sales; reading as under: “9. I have considered the facts and circumstances of the case ... next day. Thereby, it is clear that all the Sharma group of cases were used by M/s NKG Infrastructure P. Ltd. to get accommodation entries. This fact was also confirmed by Sh. Guruprasad Sharma and Sh. Dheechand Sharma under the statement recorded under section

DCIT, Central Circle-18, New Delhi vs. Guru Prasad Sharma, Ghaziabad

ITA 722/DEL/2019[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Sh. Vinay Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdqps4406L (Appellant) (Respondent) With C.O. No.60/Del/2019 [Arising Out Of Ita No.712/Del/2019] Assessment Year: 2011-12 Vs. Dcit, Sh. Vinay Sharma, B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdqps4406L (Appellant) (Respondent) With Ita Nos.716 & 717/Del/2019 Assessment Years: 2011-12 & 2012-13 Vs. Sh. Dheer Chand Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdlps0502C (Appellant) (Respondent) With C.O. Nos.64 & 65/Del/2019 [Arising Out Of Ita Nos.716 & 717/Del/2019] Assessment Years: 2011-12 & 2012-13 Vs. Dcit, Sh. Dheer Chand Sharma B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdlps0502C (Appellant) (Respondent)

Section 144Section 153ASection 37(1)

Rs.3,87,142/-; respectively as against the CIT(A)’s lower appellate discussion directing him to restrict the same @ 2.5% thereof since representing accommodation entries provided to M/s. NKG Infrastructure Limited in the form of sales; reading as under: “9. I have considered the facts and circumstances of the case ... next day. Thereby, it is clear that all the Sharma group of cases were used by M/s NKG Infrastructure P. Ltd. to get accommodation entries. This fact was also confirmed by Sh. Guruprasad Sharma and Sh. Dheechand Sharma under the statement recorded under section

DCIT, Central Circle-18, New Delhi vs. Guru Prasad Sharma, Ghaziabad

ITA 721/DEL/2019[2011-12]Status: DisposedITAT Delhi30 Jun 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Sh. Vinay Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdqps4406L (Appellant) (Respondent) With C.O. No.60/Del/2019 [Arising Out Of Ita No.712/Del/2019] Assessment Year: 2011-12 Vs. Dcit, Sh. Vinay Sharma, B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdqps4406L (Appellant) (Respondent) With Ita Nos.716 & 717/Del/2019 Assessment Years: 2011-12 & 2012-13 Vs. Sh. Dheer Chand Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdlps0502C (Appellant) (Respondent) With C.O. Nos.64 & 65/Del/2019 [Arising Out Of Ita Nos.716 & 717/Del/2019] Assessment Years: 2011-12 & 2012-13 Vs. Dcit, Sh. Dheer Chand Sharma B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdlps0502C (Appellant) (Respondent)

Section 144Section 153ASection 37(1)

Rs.3,87,142/-; respectively as against the CIT(A)’s lower appellate discussion directing him to restrict the same @ 2.5% thereof since representing accommodation entries provided to M/s. NKG Infrastructure Limited in the form of sales; reading as under: “9. I have considered the facts and circumstances of the case ... next day. Thereby, it is clear that all the Sharma group of cases were used by M/s NKG Infrastructure P. Ltd. to get accommodation entries. This fact was also confirmed by Sh. Guruprasad Sharma and Sh. Dheechand Sharma under the statement recorded under section

DCIT, Central Circle-18, New Delhi vs. Dheer Chand Sharma, Ghaziabadi

ITA 717/DEL/2019[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Sh. Vinay Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdqps4406L (Appellant) (Respondent) With C.O. No.60/Del/2019 [Arising Out Of Ita No.712/Del/2019] Assessment Year: 2011-12 Vs. Dcit, Sh. Vinay Sharma, B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdqps4406L (Appellant) (Respondent) With Ita Nos.716 & 717/Del/2019 Assessment Years: 2011-12 & 2012-13 Vs. Sh. Dheer Chand Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdlps0502C (Appellant) (Respondent) With C.O. Nos.64 & 65/Del/2019 [Arising Out Of Ita Nos.716 & 717/Del/2019] Assessment Years: 2011-12 & 2012-13 Vs. Dcit, Sh. Dheer Chand Sharma B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdlps0502C (Appellant) (Respondent)

Section 144Section 153ASection 37(1)

Rs.3,87,142/-; respectively as against the CIT(A)’s lower appellate discussion directing him to restrict the same @ 2.5% thereof since representing accommodation entries provided to M/s. NKG Infrastructure Limited in the form of sales; reading as under: “9. I have considered the facts and circumstances of the case ... next day. Thereby, it is clear that all the Sharma group of cases were used by M/s NKG Infrastructure P. Ltd. to get accommodation entries. This fact was also confirmed by Sh. Guruprasad Sharma and Sh. Dheechand Sharma under the statement recorded under section

DCIT, Central Circle-18, New Delhi vs. Dheer Chand Sharma, Ghaziabadi

ITA 716/DEL/2019[2011-12]Status: DisposedITAT Delhi30 Jun 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Sh. Vinay Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdqps4406L (Appellant) (Respondent) With C.O. No.60/Del/2019 [Arising Out Of Ita No.712/Del/2019] Assessment Year: 2011-12 Vs. Dcit, Sh. Vinay Sharma, B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdqps4406L (Appellant) (Respondent) With Ita Nos.716 & 717/Del/2019 Assessment Years: 2011-12 & 2012-13 Vs. Sh. Dheer Chand Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdlps0502C (Appellant) (Respondent) With C.O. Nos.64 & 65/Del/2019 [Arising Out Of Ita Nos.716 & 717/Del/2019] Assessment Years: 2011-12 & 2012-13 Vs. Dcit, Sh. Dheer Chand Sharma B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdlps0502C (Appellant) (Respondent)

Section 144Section 153ASection 37(1)

Rs.3,87,142/-; respectively as against the CIT(A)’s lower appellate discussion directing him to restrict the same @ 2.5% thereof since representing accommodation entries provided to M/s. NKG Infrastructure Limited in the form of sales; reading as under: “9. I have considered the facts and circumstances of the case ... next day. Thereby, it is clear that all the Sharma group of cases were used by M/s NKG Infrastructure P. Ltd. to get accommodation entries. This fact was also confirmed by Sh. Guruprasad Sharma and Sh. Dheechand Sharma under the statement recorded under section

DCIT, Central Circle-18, Ghaziabad vs. Vinay Sharma, Ghaziabad

ITA 712/DEL/2019[2011-12]Status: DisposedITAT Delhi30 Jun 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Sh. Vinay Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdqps4406L (Appellant) (Respondent) With C.O. No.60/Del/2019 [Arising Out Of Ita No.712/Del/2019] Assessment Year: 2011-12 Vs. Dcit, Sh. Vinay Sharma, B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdqps4406L (Appellant) (Respondent) With Ita Nos.716 & 717/Del/2019 Assessment Years: 2011-12 & 2012-13 Vs. Sh. Dheer Chand Sharma, Dcit, Central Circle-18, B-373, Swarnajyanti Puram, New Delhi Ghaziabad Pan: Bdlps0502C (Appellant) (Respondent) With C.O. Nos.64 & 65/Del/2019 [Arising Out Of Ita Nos.716 & 717/Del/2019] Assessment Years: 2011-12 & 2012-13 Vs. Dcit, Sh. Dheer Chand Sharma B-373, Swarnajyanti Puram, Central Circle-18, Ghaziabad New Delhi Pan: Bdlps0502C (Appellant) (Respondent)

Section 144Section 153ASection 37(1)

Rs.3,87,142/-; respectively as against the CIT(A)’s lower appellate discussion directing him to restrict the same @ 2.5% thereof since representing accommodation entries provided to M/s. NKG Infrastructure Limited in the form of sales; reading as under: “9. I have considered the facts and circumstances of the case ... next day. Thereby, it is clear that all the Sharma group of cases were used by M/s NKG Infrastructure P. Ltd. to get accommodation entries. This fact was also confirmed by Sh. Guruprasad Sharma and Sh. Dheechand Sharma under the statement recorded under section

Kundan Rice Mills Limited, New Delhi vs. Deputy Commisioner of Income Tax, Central Circle-14, New Delhi

In the result, the appeals of the Revenue are dismissed and appeals of the assessee are allowed

ITA 593/DEL/2024[2013-14]Status: DisposedITAT Delhi27 Jun 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Dayainder Singh, CIT (DR) &
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 69A

Mohit Bansal in his statement that there is no genuine business of bullion trade and M/s. Faith Jewellers Ltd. is engaged in giving accommodation entries. 3. That the appellant craves leave to add, amend, alter, or forego any ground(s) of appeal either before or at the time of hearing ... Mohit Bansal in his statement that there is no genuine business of bullion trade and M/s Faith jewelers Ltd. is engaged in giving accommodation entries. 3 That the appellant craves leave to add, amend, alter, or forego any ground/(s) of appeal either before or at the time of hearing

Deputy Commissioner of Income Tax, New Delhi vs. Kundan Rice Mills Limited, Haryana

In the result, the appeals of the Revenue are dismissed and appeals of the assessee are allowed

ITA 573/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Jun 2025AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Dayainder Singh, CIT (DR) &
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 69A

Mohit Bansal in his statement that there is no genuine business of bullion trade and M/s. Faith Jewellers Ltd. is engaged in giving accommodation entries. 3. That the appellant craves leave to add, amend, alter, or forego any ground(s) of appeal either before or at the time of hearing ... Mohit Bansal in his statement that there is no genuine business of bullion trade and M/s Faith jewelers Ltd. is engaged in giving accommodation entries. 3 That the appellant craves leave to add, amend, alter, or forego any ground/(s) of appeal either before or at the time of hearing

Deputy Commissioner of Income Tax, New Delhi vs. Kundan Rice Mills Limited, Haryana

In the result, the appeals of the Revenue are dismissed and appeals of the assessee are allowed

ITA 548/DEL/2024[2013-14]Status: DisposedITAT Delhi27 Jun 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Dayainder Singh, CIT (DR) &
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 69A

Mohit Bansal in his statement that there is no genuine business of bullion trade and M/s. Faith Jewellers Ltd. is engaged in giving accommodation entries. 3. That the appellant craves leave to add, amend, alter, or forego any ground(s) of appeal either before or at the time of hearing ... Mohit Bansal in his statement that there is no genuine business of bullion trade and M/s Faith jewelers Ltd. is engaged in giving accommodation entries. 3 That the appellant craves leave to add, amend, alter, or forego any ground/(s) of appeal either before or at the time of hearing