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“paper company”

Cash Credits & Unexplained ItemsSection 68Section 68582 judgments

The decision most relied on for paper company is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on paper company

(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. Oasis Hospitalities P. Ltd.
333 ITR 119 · 2011 · High Court
292
citing judgments

When explaining cash credits under Section 68, the assessee must establish the identity of the creditor, their creditworthiness or financial capacity, and the genuineness of the transaction. Merely proving identity does not discharge this initial onus, which shifts to the Assessing Officer once these three elements are prima facie proven.

CIT v. Nipun Builders & Developers
350 ITR 407 · 2013 · High Court
264
citing judgments

For any sum credited in an assessee's books, including share application money, the assessee must prove the identity and creditworthiness of the creditor and the genuineness of the transaction. Failure to discharge this onus under Section 68 renders the amount taxable.

CIT v. N.R. Portfolio (P.) Ltd.
42 Taxmann.com 339 · 2014 · High Court
252
citing judgments

For cash credit additions under Section 68, establishing the 'identity' of a creditor requires more than just producing PAN or assessment particulars; it necessitates demonstrating their actual business operations, place of work, staff, and public recognition. This rigorous standard ensures the assessee proves the identity, creditworthiness, and genuineness of the transaction.

CIT v. Steller Investment Ltd.
251 ITR 263 · 2001 · Supreme Court
233
citing judgments

An increase in a company's subscribed share capital cannot be treated as the company's undisclosed income under section 68, even if the subscribers to the capital are found not to be genuine. The amount of share capital cannot be regarded as undisclosed income of the company itself.

Glass Lines Equipments Company Ltd. v. CIT
253 ITR 454 · 2002 · High Court
150
citing judgments

The Assessing Officer cannot selectively accept parts of a statement or seized evidence that are favourable to the revenue while rejecting other parts favourable to the assessee without proper investigation; the evidence must be considered as a whole. Additions cannot be made based on mere presumptions or surmises without further inquiry.

CIT v. MAF Academy (P) Ltd.
361 ITR 258 · 2014 · High Court
132
citing judgments

Amounts received from bogus share transactions, where a private limited company sells shares to unrelated parties at a huge premium and then repurchases them at a loss shortly after, are taxable as unexplained cash credits under Section 68. The onus to prove identity, creditworthiness, and genuineness of such transactions lies solely on the assessee.

Judgments citing paper company

Income Tax Officer, Bkc Mumbai vs. Mukeshkumar Jain, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4664/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 Income Tax Officer Mukeshkumar Jain Room No 854B, Kautilya B/703, Plot No 46-47, Bhavan, Bkc 400051 Mumbai, Mamta Apartment, Lt Vs. Mumbai Nagar, Road No. 3, Mg Road, Goregaon West 400062, Mumbai- Mumbai Pan: Afkpj4536K (Appellant) (Respondent) Present For: Assessee By : Shri. Tejas Sodha Revenue By : Shri Praveen K. Srivastav, Ld. Sr.D.R. Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.10.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Revenue Against The Order Dated 26.06.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2017-18. 2. In This Case, The Assessee Had Declared His Total Income Of Rs. 12,48,190/- By Filing Return Of Income For The Ay Under Consideration On Dated 23.12.2017. Thereafter, The Assessing Officer (In Short ‘Ld.Ao’) On The Basis Of Information Received From The Dcit, Central Circle 7(2), Mumbai To The Effect That The Assessee Was A Beneficiary Of The Accommodation Entry Of Rs.

For Appellant: Shri. Tejas SodhaFor Respondent: Shri Praveen K. Srivastav, Ld. Sr.D.R
Section 147Section 148Section 250

However, the Assessing Officer not being impressed with the said claim of the Assessee, observed as under: “That M/s. Aneri Fincap Limited was a paper company managed and controlled by Rajesh G. Mehta, in whose group, search and seizure operation was conducted on dated 06.11.2019 and Shri. Rajesh G Mehta ... despite of issuing summons to the Directors of M/s. Aneri Fincap Limited, none appeared for examination. Thus M/s. Aneri Fincap Limited is a paper company not doing any genuine business activity and only engaged in providing bogus accommodation entries.” 5. The Ld. Commissioner in appeal, by considering the peculiar facts

Cpi India I Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle Int Tax 1(2)(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 1826/DEL/2025[2018-2019]Status: DisposedITAT Delhi31 Oct 2025AY 2018-2019

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.1826/िद"ी/2025(िन.व. 2018-19) Cpi India I Ltd. C/O Vasa Chauhan & Associates, Off. No. 41, 3Rd Floor, Hi Life Premises, P M Road, Santacruz West, Mumbai, Maharashtra 400054 ...... अपीलाथ"/Appellant Pan: Aadcc-1505-G बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri Dhanesh Bafna, (Through Vc) & Ms. Kashish Gupta, Chartered Accountants "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 05/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 31/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against Assessment Order Dated 31.01.2025 Passed U/S. 147 R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2018-19. 2. Shri Dhanesh Bafna, Appearing On Behalf Of The Assessee Submits That The Assessee Is A Tax Resident Of Mauritius. The Assesee Is An Investment Holding Company. The Assessee Has Obtained Global Business License From The Financial

For Appellant: Shri Dhanesh Bafna, (Through VC) &For Respondent: Shri M.S Nethrapal, CIT-DR
Section 112(1)(c)Section 147Section 48

contra, Shri M.S Nethrapal representing the department vehemently defended the impugned order. The ld. DR submits that the assessee is merely a paper company and has been created with sole purpose of evading tax. The ld. DR vehemently placed reliance on para 6.4.2 of DRP directions, the same is reproduced ... after making vague allegations regarding the status of the directors and structure of the company have held that the assessee is a mere paper company and is not entitled to treaty benefits. In this regard, the Panel seeks to buttress the findings and the arguments of the AO to establish

ACIT, Non-Corporate Circle 7(1), Chennai vs. Late Shri Mahaveer Bhandari, Legal Heir- Smt. Lalitha Bhandari, Chennai

ITA 2785/CHNY/2024[2016]Status: DisposedITAT Chennai15 Oct 2025

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2785/Chny/2024 िनधा"रण वष"/Assessment Year : 2016-17 The Asst. Commissioner Of Late Shri Mahaveer Bhandari, Income Tax, Rep. By Legal Heir Smt. Lalitha Non-Corporate Circle 7(1), Vs. Bhandari, Chennai. 9, Athipattan Street, Mount Road, Chennai – 600 002. Pan: Aadpb 877A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Anitha, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri Ajith Kumar Chordia, Ca (Through Virtual Mode) सुनवाई क" तारीख/Date Of Hearing : 18.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 15.10.2025

For Appellant: Ms. Anitha, Addl.CITFor Respondent: Shri Ajith Kumar Chordia, CA
Section 143(1)Section 143(3)Section 28Section 56(2)(vii)

assessee was found to be one of the beneficiaries whereby it has taken entries in the form of bogus commission expenditure from such paper company viz. M/s.Sunlight Agency P.Ltd. On the strength of this information, reasons were recorded and notice under section 148 dated 22.3.2016 was issued to the assessee ... Shri Satish Saraf Group, where Shri Rahul Jhunjunwla has admitted that he was indulged in providing accommodation entries to various companies through his paper company M/s. Sunlight Agency Pvt. Ltd. 2.4. The appellant company has claimed commission of Rs.28,03,000/-paid to M/s. Sunlight Agency