“shell company”

Cash Credits & Unexplained ItemsSection 68Section 68620 judgments

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

Leading authorities on shell 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.

Principal CIT v. Sreeleathers

448 ITR 332 · 2022 · High Court

citing judgments

Additions made by an Assessing Officer under Section 68 for unsecured loans or share capital/premium are perverse if based merely on an allegation of 'shell companies' without proper findings, especially when the assessee has provided evidence and lenders confirmed transactions through Section 133(6) notices.

CIT v. Varinder Rawlley

366 ITR 232 · 2014 · High Court

citing judgments

An assessee discharges the initial onus under Section 68 for cash credits by proving the identity and genuineness of the transaction, typically through account payee cheques, bank entries, and the creditor's PAN. The amount cannot be added as the assessee's income unless the department produces material linking the funds to the assessee or demonstrating the creditor's source flowed from the assessee, especially if the creditor is not under the assessee's control.

Major Metals Ltd. v. Union of India

19 Taxmann.com 176 · 2012 · High Court

citing judgments

When an unlisted company issues shares at an unjustifiably high premium to subscribers who lack the financial standing and creditworthiness, the entire transaction may be deemed not genuine, leading to the addition of the share capital and premium under Section 68 as unexplained cash credit.

PCIT v. Vaishnodevi Refoils & Solvex

89 Taxmann.com 80 · 2018 · High Court

citing judgments

The addition of share application money to the income of the assessee under Section 68 is not justified if the assessee has discharged the initial onus by providing complete particulars and documentary evidence of the creditor, and the Revenue has failed to prove otherwise. The Supreme Court has also dismissed the Revenue's SLP in this matter.

CIT v. Nivedan Vanijya Niyojan Ltd.

263 ITR 623 · 2003 · High Court

citing judgments

An assessee must establish the identity, creditworthiness, and genuineness of subscribers to share capital. Furnishing income tax file numbers alone is insufficient to discharge this burden.

48(SC) 2. Principal Commission of Income Tax v. NDR Promoters (P) Ltd.

96 Taxmann.com 602 · 2018 · High Court

citing judgments

The addition of share capital under Section 68 is unsustainable if the Assessing Officer issues summons to investor entities but receives no appearance, relying solely on submissions via DAK, raising doubts about investor identity and genuineness.

CIT v. Real Time Marketing (P) Ltd.

306 ITR 35 · 2008 · High Court

citing judgments

An addition under Section 68 for share application money cannot be made solely on the basis that the money deposited in the bank account of a third party was the assessee's money, if there is no material to link the assessee with the deposit.

Judgments citing shell company

DCIT, Central Circle-3(1), Kolkata vs. Gateway Financial Services Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1146/KOL/2023[2016-17]Status: DisposedITAT Kolkata30 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1146/Kol/2023 (नििाारण वर्ा / Assessment Year : 2016-2017) Dcit, Central Circle-3(1), Vs Gateway Financial Services Ltd, Kolkata 2Nd Floor, Room No.209-210, Jasmine Tower, 31, Shakespeare Sarani, West Bengal-700017 Pan No. :Aabcg 1634 L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) राजस्वकीओरसे /Revenue By : Shri P.N. Barnwal, Cit-Dr नििााररतीकीओरसे /Assessee By : Shri Akkal Dudhwewala, Fca सुिवाई की तारीख / Date Of Hearing : 09/07/2025 घोर्णा की तारीख/Date Of Pronouncement : 30/07/2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Revenue Against The Order Dated 27.07.2023, Passed By The Ld. Cit(A), Kolkata-21, For The Assessment Year 2016-2017. 2. This Appeal Is Barred By 25 Days. Looking To The Facts & Circumstances Of The Case, The Delay Of 25 Days In Filing The Appeal Is Condoned & The Appeal Is Admitted & Disposed Off Accordingly. 3. The Only Issue Raised By The Revenue Is Against The Deleting The Addition Of Rs.15.05 Crores By The Ld. Cit(A) As Made By The Ao U/S.68 Of The Act In Respect Of Unsecured Loan Received By The Assessee During The Year.

For Appellant: Shri Akkal Dudhwewala, FCAFor Respondent: Shri P.N. Barnwal, CIT-DR

Section 133(6)Section 147Section 148Section 68Section 69C

reopened the assessment after an information received from DDIT(Inv.) Unit-1(2), Kolkata that the assessee had received Rs.15.05 crores from shell company M/s Juhi Advisory Pvt. Ltd.by issuing notice u/s.148 of the Act on 05.03.2021, which was duly served on the assessee, the assessee filed return of income ... order of the ld.CIT(A). 7. The argument presented by the ld. CIT-DR is devoid of merit that the loan was received from shell company which is not having any purchase and sales or the fixed assets. We have examined the audited 5 accounts filed before

Vidarbha Mining Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1(3)(2), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 1265/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Padmavathy S., Am Vidarbha Mining Private Limited Deputy Commissioner Of Income 703, Samarpan Complex, Near Mirador Tax, Circle-1(3)(2), Mumbai Room No. 540, 5Th Floor, Aayakar Hotel, New Link Road, Chakala, Andheri (East), Mumbai – 400099. Vs. Bhavan, Maharshi Karve Rd, New Marine Lines, Churchgate, Mumbai – 400020. Pan/Gir No. Aaccv2506M (Assessee) : (Respondent) Assessee By : Shri. Gaurav Kabra Respondent By : Shri. G. J. Ninawe, Sr. Dr Date Of Hearing : 01.05.2025 Date Of Pronouncement : 30.07.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals)-Delhi (‘Ld. Cit(A) For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal & Has Also Filed Additional Grounds Which Are As Follows: Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case As Well As In Law, The Learned Cit(A) Has Erred In Confirming The Action Of Learned Assessing Officer In Reopening The Assessment U/S.147 Of The Act, Without Appreciating The Fact & Circumstances Of The Case. Vidarbha Mining Private Limited Vs. Dy. Cit

For Appellant: Shri. Gaurav KabraFor Respondent: Shri. G. J. Ninawe, SR. DR

Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 153CSection 250Section 68

Sthapna Properties P.Ltd, New Delhi vs. ITO, Ward-24(2), New Delhi

The appeal of the assessee is allowed

ITA 1588/DEL/2019[2013-14]Status: DisposedITAT Delhi30 Jul 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2013-14 M/S Sthapna Properties Private Vs Ito, Ltd., Ward 24(2), 108, South Ex. Plaza Ii, New Delhi. South Ex. Part Ii, New Delhi – 110 049. Pan: Aancs1478C (Appellant) (Respondent) Assessee By : Shri Ajay Wadhwa, Advocate; Ms Ragini Handa, Advocate; & Shri Saksham Garg, Ca Revenue By : Shri Dheeraj Kumar Kain, Sr. Dr Date Of Hearing : 01.07.2025 Date Of Pronouncement : 30.07.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Dheeraj Kumar Kain, Sr. DR

Section 131Section 133(6)Section 143(3)Section 68

appellant produced the Principal Officer before the AO for examination. C. The identity, creditworthiness and genuineness remained totally unexplained. The Company was only a shell company existing on papers for providing accommodation entries. D. As per the first Proviso to section 68, the appellant is required to explain the nature ... genuineness of the transaction. The order of the ld.CIT(A) goes 12 to show that based on broad assumptions about as to how the shell companies work the transaction of investment has been doubted. The spot inquiry of the addresses cannot be a conclusive proof of the existence

Prayag Capitals India Limited, Allahabad vs. ITO, Ward-2(2) Now Ward-2(1), Allahabad

In the result, the appeal of the assessee stands allowed

ITA 81/ALLD/2024[2015-16]Status: DisposedITAT Allahabad29 Jul 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)

capacity to contribute the share capital of Rs.70,00,000/-. It appears that the M/s Sakshi Barter Pvt. Ltd. is entry operator or shell company. Thus the creditworthiness the share holder is net proved, therefore the deposit of Rs.70,00,000/- as share capital is income of the assessee from

Shri Amit Mangilal Jain, Mumbai vs. ACIT, - 33(1), Mumbai

In the result, both the above appeals are allowed

ITA 3332/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Jul 2025AY 2010-11

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Naresh Jain & Shri Mahaveer Jain, ARsFor Respondent: Shri Ram Krishn Kedia, (Sr. DR)

Section 131Section 143(3)Section 147Section 148Section 153C

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

other forms and assessee is one of the beneficiary company who has taken accommodation entry of Rs. 14, 19, 53,079/- from these paper/ shell companies, issued notice u/s. 148 of the Act dt. 29.03.2019. The reasons recorded for issuance of notice u/s. 148 of the Act as mentioned ... received from DDIT (Inv), Unit-1(3) vide letter no. DDIT (Inv)/Unit- 1(3)/Kol/Banka/Information/2018-19/8077 dated 26.2.2019. As per information various paper/ shell companies controlled and managed by Sh. Mukesh Banka were identified as engaged in providing accommodation entries in the nature of bogus unsecured loans or in other

DCIT CC 7(3), Mumbai vs. M/S Tirupati Developers, Mumbai

In the result, both the appeal of the revenue and CO of the assessee are

ITA 2165/MUM/2019[2012-13]Status: DisposedITAT Mumbai21 Jul 2025AY 2012-13

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhriआयकर अपील सं./Ita No. 2165/Mum/2019 (निर्धारण वर्ष / Assessment Year :2012-13) Dcit Cc – 7(3), Room No. 655, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020 V/S. बनाम M/S. Tirupati Developers. 419, Laxmi Plaza, Laxmi Industrial Estate, New Link Road, Andheri (W.), Mumbai-400053 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaeft6810B Appellant/अपीलार्थी .. Respondent/प्रतिवादी प्रति आपत्ति सं./ Co No. 110/Mum/2021 (Arising Out Of Ita No. 2165/Mum/2019) (निर्धारण वर्ष / Assessment Year :2012-13) M/S. Tirupati Developers. V/S. Dcit Cc – 7(3), 419, Laxmi Plaza, Laxmi बनाम Room No. 655, 6Th Floor, Industrial Estate, New Aayakar Bhavan, M. K. Link Road, Andheri (W.), Road, Mumbai-400020 Mumbai-400053 Appellant/अपीलार्थी .. Respondent/प्रतिवादी स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaeft6810B निर्धारिती की ओर से /Assessee By: Shri Rushabh Mehta राजस्व की ओर से /Revenue By: Shri Biswanath Das सुनवाई की तारीख / Date Of Hearing 18.07.2025 घोषणा की तारीख/Date Of Pronouncement 21.07.2025 Page 2

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Biswanath Das

Section 132Section 143(3)Section 153ASection 250Section 68

active in the website of MCA and none of the companies' name is struck off from the list published by the MCA as shell company. We further notice that the assessee has filed balance- sheet of all 9 subscribers wherein they have huge share capital and reserves and surplus

Niranjan Kumar Sharma, Hooghly vs. I.T.O., Ward - 23(1), Hooghly

Appeal is partly allowed for statistical purposes

ITA 27/KOL/2025[2018-2019]Status: DisposedITAT Kolkata17 Jul 2025AY 2018-2019

Bench: The Ld. Cit(A) Where Also He Could Only Partially Succeed Since The Ld. Cit(A) Remanded The Matter Back To The File Of Ld. Ao With The Direction To Afford An Opportunity

Section 144Section 147Section 148Section 250Section 68

case, the Ld. AR stated that the impugned transactions were with a corporate entity which was registered with ROC and was not a shell company, as has been alleged by the Ld.AO. 2.1 The Ld. DR pointed out that the case of Hexaware Technologies Ltd. (supra) was pending before

Bsas Infortech Limited, Surat vs. Assistant Commissioner of Income Tax, Circle - 1(1)(1), Surat

In the result, appeal filed by the assessee is treated as allowed

ITA 226/SRT/2024[2016-17]Status: DisposedITAT Surat15 Jul 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri P M Jagasheth, CAFor Respondent: Shri Ajay Uke, Sr. DR

Section 147Section 148Section 68Section 69

bogus paper concern/companies. On the basis of report of Investigation Wing, Mumbai, it is clearly found that M/s. Vanguard Jewels Pvt. Ltd. is proved shell company, handled by Shri Pravin Kumar Jain, an entry provider. …. 4. In light of the discussion held above, accommodation entry in the form of unsecured

Bsas Infotech Limited, Surat vs. Dy. Commissioner of Income Tax, Circle - 1(1)(1), Surat

In the result, appeal filed by the assessee is treated as allowed

ITA 225/SRT/2024[2015-16]Status: DisposedITAT Surat15 Jul 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri P M Jagasheth, CAFor Respondent: Shri Ajay Uke, Sr. DR

Section 147Section 148Section 68Section 69

Bsas Infotech Limited, Surat vs. Dy. Commissioner of Income Tax, Circle -1(1)(1), Surat

In the result, appeal filed by the assessee is treated as allowed

ITA 224/SRT/2024[2011-12]Status: DisposedITAT Surat15 Jul 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri P M Jagasheth, CAFor Respondent: Shri Ajay Uke, Sr. DR

Section 147Section 148Section 68Section 69

Sajal Impex Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

The appeal of the assessee is allowed

ITA 265/KOL/2025[2012-13]Status: DisposedITAT Kolkata15 Jul 2025AY 2012-13

Bench: Shri Duvvuru Rl Reddy & Shri Rakesh Mishraay 2012-13 Income Tax Officer, Sajal Impex Pvt. Ltd. Ward 12(1), 4, Synagogue Street, Vs. Aaykar Bhawan, Kolkata-700001, West Bengal P-7, Chowringhee Square, (Pan: Aahcs5794D) Kolkata-700069, West Bengal (Appellant) (Respondent) Present For: Appellant By : Shri Miraz D Shah, Ar Respondent By : Shri S.B. Chakraborty, Dr Date Of Hearing : 17.06.2025 Date Of Pronouncement : 15.07.2025 O R D E R Per Rakesh Mishra: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi (Hereinafter Referred To As “The Ld. Cit(A)”) Passed U/S. 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ay 2012-13 Dated 28.11.2024. 02. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Un- Der:

For Appellant: Shri Miraz D Shah, ARFor Respondent: Shri S.B. Chakraborty, DR

Section 133(6)Section 139(1)Section 142(1)Section 147Section 148Section 250Section 68

Ward i.e. Ward 12(1) Kolkata. It is further submitted that recurrence of non- response strongly indicates that M/s. Divyadrishti Merchants P Ltd. is shell company and transaction made by the assessee with this company was noth- ing but book entries. 5.4.1 In the assessment order, the AO held that ... brought back its unaccounted income in the books of accounts to the tune of Rs. 98,95,752/- through bank account No. 605010065 from shell company M/s. Divya Drishti Merchants P Ltd. It has seen that the appellant company has received money from companies having dubious creditworthiness and fictitious paper

Kalavathi Devi Sharma, Hyderabad vs. ITO, Ward-1, Nanded

In the result, appeal of the assessee is dismissed

ITA 1519/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri S. Sadananda Singh, JCIT

Section 10(38)Section 147Section 148Section 148ASection 149Section 250Section 68

providing fictitious long term capital gain to multiple entities and the financials clearly show that 8 Kalavathi Devi Sharma the company is a shell company. It was noticed that the appellant is one such beneficiary who received fictitious LTCG during the year under appeal. The Appellant did not furnish

Amol Ceramica Private Limited, Mumbai vs. Income Tax Officer 9.1.2, Churchgate

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 2013/MUM/2025[21017-18]Status: DisposedITAT Mumbai14 Jul 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailamol Ceramica Pvt. Ltd., 355, Powai Plaza, Hiranandani Garden Powai, Mumbai - 400076 ............... Appellant Pan : Aaaca4899G V/S Ito – 9(1)(2), 205, Aaykar Bhawan, ……………… Respondent M.K. Road, Church Gate, Mumbai - 400020 Assessee By : Shri R.S. Sharma Revenue By : Shri Aditya M. Rai, Sr.Dr

For Appellant: Shri R.S. SharmaFor Respondent: Shri Aditya M. Rai, Sr.DR

Section 115Section 115JSection 142(1)Section 143(2)Section 143(3)Section 250Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

M/S Vinayak Financial Consultants Private Limited, Kolkata vs. D.C.I.T., Central Circle-4(1), Kolkata

In the result, appeal of the assessee is partly allowed for statistical

ITA 2695/KOL/2024[2013-14]Status: DisposedITAT Kolkata10 Jul 2025AY 2013-14

Bench: Shri George Mathan

For Appellant: Shri A.K.Tulsyan & Shri RobinFor Respondent: Smt. Madhumita Das, Sr.DR

Section 139(1)Section 143(1)Section 147Section 148

immediately transferred to various other companies. On perusal of the bank account it was found that funds were credited in this account from various shell companies and the same was transferred to beneficiary companies on the same day or near about dates. There was no other financial rationale behind such ... said reasons, you have made allegation that the company has reeived Rs.10,00,000/- from M/s Shivashiv Dealtrade Pvt Ltd, alleged to be shell company. However, you have not mentioned whether said amount is receive as loan or advance, or share capital or against sale or for any other reason

Savita Gupta, Kota vs. ITO, Delhi

ITA 609/JPR/2025[2013-14]Status: DisposedITAT Jaipur09 Jul 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Vinod Kumar Gupta, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 132Section 133(6)Section 142(1)Section 147Section 148Section 69

Revenue had provided accommodation entries to the petitioner, in which it was also revealed 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 and seizure ... Revenue had provided accommodation entries to the petitioner, in which it was also revealed 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 and seizure

Dy. Commissioner of Income Tax, Mumbai vs. Shree Thirumalai Marketing & Investments Limited, Mumbai

In the result, both the appeals filed by the revenue in ITA Nos

ITA 474/MUM/2025[2023-14]Status: DisposedITAT Mumbai08 Jul 2025AY 2023-14

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Varun BrahmechaFor Respondent: Shri Hemanshu Joshi, SR DR

Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

assessee has failed to establish that the 1oan creditors are genuine. The lender companies have been used by the 12.18 The above bogus entities / shell companies have been used as conduit or layer to route the assessee’s unaccounted money in the guise of unsecured loan. Further, field verification done

Dy. Commissioner of Income Tax (Central Circle)-2(3), Mumbai vs. Shree Thirumalai Marketing & Investments Limited, Mumbai

In the result, both the appeals filed by the revenue in ITA Nos

ITA 139/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Jul 2025AY 2013-14

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Varun BrahmechaFor Respondent: Shri Hemanshu Joshi, SR DR

Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

Eastern and Western Dresses Trading Private Limited, New Delhi vs. ITO Ward-8(1), New Delhi

Appeal is dismissed

ITA 1939/DEL/2020[2011-12]Status: DisposedITAT Delhi03 Jul 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Income Tax Officer, M/S. Eastern & Western Dresses Trading Pvt. Ltd., Ward-8(1), No. 7, Shankar Vihar, New Delhi New Delhi Pan: Aabce5153G (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr

Section 143(3)Section 68

income of the Assessee (AY. 2009-10) 6,4 Royal Rich Development Pvt. Ltd. v. PCIT (Bom)(HC) Cash credits Bogus share capital-Shell company -Huge premium- Failure to produce the subscribers and based on the statement of the Director that entire invest was bogus-Addition is held ... genuineness of transaction has to be determined by ground realities and not by documents like PAN cards, board resolutions, share certificates etc. as even shell companies have these documents. 6.17 The AR of the appellant has also relied on several case laws. I have carefully perused the same and found

The Assistant Commissioner of Income Tax, Circle-1(1), Vijayawada vs. Vedmutha Electricals India Private Limited, Vijayawada

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 38/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2017-18

Bench: Us:

For Appellant: None

Section 131Section 147

Vedumutha Electricals India Private Limited. beneficiaries through rigging of shares. Further, the name of the said company had figured in the list of confirmed shell companies as circulated by FIU IND. Also, the entry operators and exit providers in their statements had admitted that the scrip of “Essar India Limited ... accommodation entries to various beneficiaries through the rigging of shares. Further, the name of the said company had figured in the list of confirmed shell companies as circulated by FIU IND. Also, the A.O. had observed that the entry operators and exit providers in their statements had admitted that