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“shell company”

Cash Credits & Unexplained ItemsSection 68Section 68620 judgments

DCIT, CENTRAL CIRCLE-30, NEW DELHI vs. SHALIMAR CORP. LTD, MUMBAI

In the result, the appeal of the assessee in ITA No

ITA 3068/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Subhash Aggarwal, AdvFor Respondent: Shri Mahesh Rajani, CIT-DR
Section 143(3)Section 153ASection 68

3068/DEL/2022 Shalimar Corp [A.Y. 2017-18) Nihon Impex Pvt Ltd against the assessee, and held Nihon Impex as a shell company from whom the assessee had taken accommodation entry, and added the same u/s 68. 27. When the assessee went in appeal before ... drawn in their assessment. 30. The ld AR stated that the ld. CIT(A) held that the Assessing Officer held Nihon Impex as shell company, without marshalling evidences whereas the assessee has furnished all necessary documents to discharge the initial onus. It is submitted that Hon'ble Delhi High Court

SHALIMAR CORP LTD,LUCKNOW vs. DCIT, CENTRAL CIRCLE-30, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2769/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Subhash Aggarwal, AdvFor Respondent: Shri Mahesh Rajani, CIT-DR
Section 143(3)Section 153ASection 68

3068/DEL/2022 Shalimar Corp [A.Y. 2017-18) Nihon Impex Pvt Ltd against the assessee, and held Nihon Impex as a shell company from whom the assessee had taken accommodation entry, and added the same u/s 68. 27. When the assessee went in appeal before ... drawn in their assessment. 30. The ld AR stated that the ld. CIT(A) held that the Assessing Officer held Nihon Impex as shell company, without marshalling evidences whereas the assessee has furnished all necessary documents to discharge the initial onus. It is submitted that Hon'ble Delhi High Court

DCIT-4(1), INDORE, INDORE vs. RAJAT SUREKA, INDORE

The appeal is allowed

ITA 426/IND/2025[2014-15]Status: DisposedITAT Indore20 Mar 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Dcit 4(1), Rajat Sureka, Indore D-41, Hig Colony, बनाम/ A.B. Road, Vs. Indore (Revenue/Appellant) (Assessee/Respondent) Pan: Aksps7189J Revenue By Shri Ashish Porwal, Sr. Dr Assessee By Shri Subhash Chandra, Ar Date Of Hearing 19.03.2026 Date Of Pronouncement 20.03.2026

Section 139Section 147Section 148Section 68Section 69Section 69C

without appreciating the finding of the AO and his observation in respect of findings of the Investigation Wing and that of the SEBI w.r.t shell companies managed Page 1 of 5 Rajat Sureka ITA No. 426/Ind/2025 – AY 2014-15 by Shri Sharad Darak wherein it was established that the same ... facts of the case and finding of the AO that the company M/s Jayant Security and Finance Pvt. Ltd is established to be a shell company which provided accommodation entry after charging commission.” 2. The background facts leading to present appeal are such that the assessee-individual filed his return

JCIT, (OSD), CIRCLE 1(1), RAIPUR, RAIPUR vs. MAHENDRA KUMAR GUPTA HUF, RAIPUR, RAIPUR

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

ITA 131/RPR/2026[2011-12]Status: DisposedITAT Raipur10 Mar 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.131/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 The Joint Commissioner Of Income Tax (Osd), Circle-1(1), Raipur (C.G.)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 133(6)Section 147

Appeals)/NFAC so that the remand report can be submitted by the A.O since this issue of bogus purchases and accommodation entries involving shell companies has huge impact on the financial economy of the country. 5. I find force in the contention raised by the Ld. Sr. DR since nothing ... case pertaining to the assessee and since in this case, the issue is with regard to the bogus purchases operated through brokers, intermediaries shell companies which creates a vacuum so far as the legitimate collection of tax is concerned, therefore, it is of utmost importance to have ground verification done

SURESH KUMAR PODDAR,KOLKATA vs. I.T.O., WARD - 63(4), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

ITA 1542/KOL/2024[2011-2012]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-2012

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 111ASection 132Section 132(1)Section 139(1)Section 144Section 147Section 148Section 153CSection 250Section 250o

Revenue had pro- vided accommodation entries to the petitioner, in which it was also re- vealed that Green Valley Gems Pvt. Ltd. was a shell company. We do not find that the record would indicate something which is not on the basis of such new materials gathered under the search

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue's appeals are dismissed and assessee's appeals are\npartly allowed

ITA 4007/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Feb 2026AY 2018-19
Section 132Section 143(3)Section 68

nshell company, which raises bogus sales invoices to the second\ncompany (Vinod Jatia group of companies). Second company made\nthe payment to the shell company through the LC issued by the\nBank. Thus, the shell company received the money without selling\nany goods, but only for generating bogus invoices ... 133A, field visit by the inspectors and the\nanalysis of the financial statements reveal that the parties with\nwhom such transactions were booked are shell companies, created\non paper.\nh) Directors, entry operators or key people of the parties with whom\ntransactions were made have admitted during the search that

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3993/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3976/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3975/MUM/2025[2014-15]Status: DisposedITAT Mumbai27 Feb 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3972/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE -7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3146/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Feb 2026AY 2019-20

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3145/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3144/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3143/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Feb 2026AY 2016-17

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

SUPERWAYS ENTERPIRSES PRIVATE LIMITED LTD ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

ITA 3142/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Feb 2026AY 2015-16
Section 132Section 143(3)Section 68

nshell company, which raises bogus sales invoices to the second\ncompany (Vinod Jatia group of companies). Second company made\nthe payment to the shell company through the LC issued by the\nBank. Thus, the shell company received the money without selling\nany goods, but only for generating bogus invoices ... 133A, field visit by the inspectors and the\nanalysis of the financial statements reveal that the parties with\nwhom such transactions were booked are shell companies, created\non paper.\nh) Directors, entry operators or key people of the parties with whom\ntransactions were made have admitted during the search that

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3140/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

under:- a) The modus operandi followed by the group companies is that main company (Topworth Group, Uttam Group or Llyod Group) formed a shell company, which raises bogus sales invoices to the second company (Vinod Jatia group of companies). Second company made the payment to the shell company through ... issued by the Bank. Thus, the shell company received the money without selling any goods, but only for generating bogus invoices. b) During the course of search, post search and assessment proceedings, assessee could not produce basic details such as the stock register, transportation details, communication with vendor & customers, weighment

RAJENDRA KUMAR KAPOOR,KOLKATA vs. D.C.I.T., CIRCLE - 29,, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2060/KOL/2025[2018-2019]Status: DisposedITAT Kolkata26 Feb 2026AY 2018-2019
Section 139(5)Section 147Section 148Section 68

Finally, the Id. AO made the addition\nof the said amount as unexplained cash credit on the ground that\nloan was received from a shell company which remain unexplained.\nThe Id. AO made the addition on the ground that the show cause\nnotice was not replied by the assessee ... loan confirmation, PAN details, address and audited\nbalance sheet etc. According to the Id. AO the loan was received from\na shell company and the same was added to the income of the\nassessee. We also note that the Id. CIT (A) recorded a finding in the\nappellate order that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(3), KOLKATA, KOLKATA vs. AVIMA EXPORTS PRIVATE LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 1599/KOL/2025[2016-17]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-17
Section 131Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 68

Gupta, directors and key persons of the said group had admitted on oath that the assessee was involved in availing accommodation entry from several shell companies in the form of unsecured loans. The AO had also alleged that the list of such shell companies includes the name of the above ... lending entities as well as the assessee company. Hence, the AO had opined that the said unsecured loans were received by the assessee from shell companies and the said loans are bogus.\n6.2.3. However, the AO had failed to appreciate the fact that the statement as relied

SHEETAL RAJEEV GADRE,MUMBAI vs. ITO WARD 34(3)(2), MUMBAI

ITA 8534/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Ashish ThakurdesaiFor Respondent: Shri Bhagirath Ramawat
Section 115BSection 144Section 144BSection 147Section 148ASection 151ASection 68

transactions, or justification for abnormal price movements in the scrip. 6.2.3 The Investigation Wing's findings show that Oasis Tradelink Ltd. was a shell company used for providing artificial gains and losses through synchronized trades. The assessee's name figures among the beneficiaries of this network. 6.2.4 Merely producing contract

DCIT(IT)-4(1)(2), MUMBAI vs. ARUN MADHAVACHARI RANGACHARI, MUMBAI

ITA 3814/MUM/2025[2011-12]Status: DisposedITAT Mumbai26 Feb 2026AY 2011-12
For Appellant: Shri Gaurav KabraFor Respondent: Shri Ajay Chandra, CIT-DR
Section 250Section 254Section 9(1)(vii)

activities have been\ncarried out by the assessee himself. Thus, the AO held that both, i.e.,\nDAR Capital Ltd. and Thurles International Ltd., are shell companies\nexisting only on paper, based in tax havens to avoid taxation in India.\nAccordingly, the AO held that INR 465 crore received ... provide the necessary information which\nwas sought, the two non-resident companies, i.e. DAR Capital Ltd. and\nThurles International Ltd., were held to be shell companies of the\nassessee in India, as he was the 100% shareholder of these two\ncompanies. Accordingly, the entire sum of INR 465 crore

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