“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

ACIT Circle-59(1), New Delhi vs. Sanjay Singhal & Sons (HUF), New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 281/DEL/2021[2015-16]Status: DisposedITAT Delhi16 Oct 2023AY 2015-16

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 281/Del/2021 : Asstt. Year : 2015-16 Acit, Vs Sanjay Singhal & Sons (Huf), Circle-59(1), 9-110, Saraswati Kunj, 8, Alipur New Delhi Road, Delhi-110054 (Appellant) (Respondent) Pan No. Aaihs6800C Assessee By : Sh. Amit Goel, Ca Revenue By : Sh. Amit Katoch, Sr. Dr Date Of Hearing: 17.07.2023 Date Of Pronouncement: 16.10.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Amit Goel, CAFor Respondent: Sh. Amit Katoch, Sr. DR

Section 131Section 133(6)Section 143(3)Section 54Section 68

actual business in the company. The AO held that this gives rise to strong suspicion that company was a front or a shell company and existed on paper only. AO issued summons u/s 131 to Director of this company but none appeared and only written submissions like Balance Sheet ... Account and other documents were filed before the AO. The name of SMS ITS PL. did not figure in list of shell companies as per ROC. The AO noted that the recent list of shell companies released by ROC is inclusive list and not exhaustive list. Merely because

ACIT, CC- 30, New Delhi vs. J H Jewellers LLP, New Delhi

In the result, the appeal of Revenue is dismissed

ITA 809/DEL/2021[2016-17]Status: DisposedITAT Delhi13 Oct 2023AY 2016-17

Bench: Shri Chandra Mohan Garg & M.Balaganeshassessment Year: 2016-17 The Dcit, Central Circle-30, New Delhi M/S. J H Jewellers Llp, 13, Sunder Nagar Market, Kasturba Vs. Nagar, South East, Delhi 110003 Pan Aacfj 3285 G (Appellant) (Respondent) For Revenue: Shri Waseem Arshad, Cit(Dr) For Assessee: Shri U.N Marwah, Ca Shri Parveen Goel, Adv. Date Of Hearing : 23.08.2023 Date Of Pronouncement : 13.10.2023 Order Per Chandra Mohan Garg, J.M. This Appeal Has Been Filed Against The Order Cit(A)-30, New Delhi Dated 25.03.2021 For A.Y. 2016-17. 2. The Grounds Have Been Raised By The Revenue Are As Follows:- 1. The Cit(A) Has Erred In Law & On The Facts In Deleting The Rs.11,24,76,000/- Additions Of Rs. 32,50,00,000/- Made U/S 68 Of The It Act 1961. 2. The Cit(A) Has Erred In Law & On The Facts Of The Case Considering That As Per The Balance Sheet Of These Companies As On 31.03.2016, The Said Fund Were Available In The Balance Sheet Of All The Four Companies Under The Head "Cash & Cash Equivalents" As On 31.03.2015 Which Are Now Reflected In Current Investment In I.E. Investment As Capital In The Appellant Firm As On31.03.2016. Further, Relying On The Submission Of The Assessee That The Said Four Companies Introduced Funds In The Ay 2008-09, The Case Of Maharaja Tie Up, Dynamic Enclave & Shivshakti Commercial Pt Ltd Were Assessed W/S 147 Of The Act For A.Y. 2008-09 Accepting The Share Capital/Share Premium.

For Appellant: Shri U.N Marwah, CAFor Respondent: Shri Waseem Arshad, CIT(DR)

Section 68

that company has no furniture and fixtures, and no expense on account of rent, telephone expense, and electricity expense. These are typical nature of shell company. Thirdly, during the course of assessment in the case of M/s Maharaja Tie up Pvt. Ltd., only on the test check basis notice ... companies which become share holders in 3 companies in F.Y.2007-08 did not have creditworthiness to advance huge amount of funds and they were merely shell companies. 4. The Ld. CIT(A) has erred in law or facts by holding in para 9.10 of the appeal order that genuineness

Deepak Singhal, New Delhi vs. ITO Ward - 36(4), New Delhi

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

ITA 1321/DEL/2020[2015-16]Status: DisposedITAT Delhi12 Oct 2023AY 2015-16

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 68Section 69Section 69C

facts and in the circumstances of the case and in law, the CIT(A) erred in holding that M/s.Consolidated Infracon (P) Ltd. was a shell company, failing to note that in the assessment orders for the said company placed on record, no adverse inference was drawn; 6. On the facts

Rpg Nirman P.Ltd, Meerut vs. DCIT, Central Circle, Meerut

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3026/DEL/2022[2017-18]Status: DisposedITAT Delhi06 Oct 2023AY 2017-18

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

Rs.66,32,000I-. However, on investigation it was found that the loan was not genuine. The loan was provided by accommodation entries through shell companies operated by Sri Dharmendra Gupta. Shri Dharmendra Gupta had promoted around 21 companies whose primary purpose was. to provide accommodation entries. When asked about ... giving loans and advances does not commensurate with the returned income. In fact, a typical structure of the entire transaction resembling those of a shell company was found. The gross total income of these companies is constantly found to be very low yet they are having huge loans and advances

Rpg Nirman (P) Ltd., Meerut vs. DCIT, Central Circle, Meerut

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3025/DEL/2022[2016-17]Status: DisposedITAT Delhi06 Oct 2023AY 2016-17

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

Rpg Nirman (P) Ltd., Meerut vs. DCIT, Central Circle, Meerut

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3024/DEL/2022[2015-16]Status: DisposedITAT Delhi06 Oct 2023AY 2015-16

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

Rpg Nirman (P) Ltd., Meerut vs. DCIT, Central Circle, Meerut

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3023/DEL/2022[2014-15]Status: DisposedITAT Delhi06 Oct 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

DCIT-CC-27, New Delhi vs. Anshika Consultants Pvt Ltd., New Delhi

In the result, Appeal of the Revenue is partly allowed for

ITA 35/DEL/2022[2015-16]Status: DisposedITAT Delhi13 Sept 2023AY 2015-16

Bench: Or At The Time Of Hearing Of The Appeal.” Cross Objection

Section 115JSection 136(6)Section 143(3)Section 14ASection 68

interest bearing loans and the related interest income is duly reflected in the ITR of the creditor companies. regarding the creditor company being a shell company on the basis of common Further, the AO's finding directors among group companies and rotation of funds among group companies, is unfounded since ... related interest income is duly reflected in the ITR of the creditor companies. Further, the AO's finding regarding the creditor company being a shell company on the basis of common directors among group companies and rotation of funds among group companies, is unfounded since there is nothing unusual about

Aarti Sponge and Power Ltd., Raipur vs. Pr. Commissioner of Income Tax, Raipur - 1, Raipur

In the result, appeal of the assessee stands dismissed

ITA 78/RPR/2022[2014-15]Status: DisposedITAT Raipur06 Sept 2023AY 2014-15

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Appellant: Shri R. B. Doshi, CAFor Respondent: Shri S. K. Meena, CIT-DR

Section 14ASection 263

erroneous or prejudicial. iii) Nothing brought on record b\ Id. Pr. CIT to show how the lender Angad Chemical Pvt. Ltd. is branded as shell company. Arbitrary and unsubstantiated allegation levelled. Lender being a private company, no question of it being regulated by SF.BI & consequently, SFBI publishing any list containing ... respect of these two loans, nothing brought on record nor confronted to the assessee as to how these two companies arc branded as shell companies. Arbitrary and baseless allegation. Both are private companies, not regulated by SF.BI and no question of SFBI publishing any list containing name of such unregulated

Income Tax Officer, Ward 2(1), Raipur vs. Mesers Aryan Builders and Developers Private Limited, Raipur

In the result, both appeal of the revenue and cross objection of the assessee stand dismissed in terms of our observations

ITA 201/RPR/2018[2012-13]Status: DisposedITAT Raipur06 Sept 2023AY 2012-13

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Appellant: Shri Ramesh Kumar Singhania, CA, &For Respondent: Shri S.K.Meena, CIT-DR

Section 143(2)Section 250(4)Section 68

such notice u/s 133(6) documents like PAN cards, board resolutions, share was issued for conducting certificates etc. as even shell companies have these enquiry and no such documents. If the assessee is not able to produce the responses was made by the brains behind these companies and the documents ... with respect to their financials the transaction 133(6) notices cannot regarded as genuine. [Para- 3.8 of SOF) • • The investor companies were identified as shell companies. • case of Hon’ble IT AT, New Delhi (A Bench) in the case of M/s Pee Aar Securities Ltd. Vs. DC1T- Circle

ITO WD.5(1) (1), Mumbai vs. M/S. Ams Trading & Investment Pvt. Ltd, Mumbai

ITA 1863/MUM/2021[2010-11]Status: DisposedITAT Mumbai25 Aug 2023AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahman Ito – Ward 5(1)(1), Amstrading&Investment Room No.570, 5Th Pvt Ltd.,1St Floor, बनाम/ Floor, Shatrunjayapartments, Vs. Aayakar Bhavan, 28 Sindhi Lane, M.K.Road, Nanubhai Desai Road, Mumbai- 400020. Mumbai – 400004. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aafca6183N (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Smt.Sujatha Iyangar.DRFor Respondent: Shri.AjaySingh&ShriYogesh Joijode.AR

Section 132(4)Section 143(3)Section 148Section 68

circumstances of the present case" 10We have also made enquiry from the learned SrDepartmental Representative, whether the investors or this company is a Shell company or in the list prepared by Ministry of Corporate Affairs, Govtof India. The learned Sr. DR, stated that this information is not available with

ACIT-1(1)(1), Mumbai vs. M/S. Anantnath Silk Mills Private Limited, Mumbai

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

ITA 1776/MUM/2023[2018-19]Status: DisposedITAT Mumbai21 Aug 2023AY 2018-19

For Appellant: Shri Manoj Kumar Sinha (Sr. AR)For Respondent: Shri Vimal Punmiya (DR)

Section 133(6)Section 68

bank statement (of M/s. Tuni) that there was meagre balance throughout the year. And that the SFIO, has termed it to be shell company. Therefore, AO was of the view that the assessee failed to prove the identity, creditworthiness and genuineness of the 2 A.Y. 2018-19 M/s. Anantnath Silk ... therefore, the AO did not get proper opportunity to verify the financial of the lender company (M/s. Tuni) which according to him is a shell company as found by SFIO. Therefore, he prays that the impugned order of the Ld. CIT(A) may be set aside back to the file

Subhshree Investment Management P.Ltd, New Delhi vs. ACIT, Central Circle-8, New Delhi

In the result, this appeal filed by the assessee stands dismissed

ITA 1095/DEL/2019[2009-10]Status: DisposedITAT Delhi09 Aug 2023AY 2009-10

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Us[Assessment Year: 2009-10]

Section 147Section 148Section 153CSection 68

parties extensively in this case. He also noted that the reply of the assessee. In reply, the assessee tried to suggest that it is Shell Company without having any assets of its own and that the assessee has only dealing book entries. However, the AO was not satisfied ... also not convinced with the assessee’s reply. He observed as under:- “The appellant has contended that if these were actual assets in these shell companies then these would have been taken over by the Priya Gold Group Companies, which would be the recipient of these assets. On due consideration

Surya Vanijya P.Ltd, New Delhi vs. ACIT, Central Circle-8, New Delhi

In the result, the Appeal filed by the assessee is dismissed

ITA 1099/DEL/2019[2009-10]Status: DisposedITAT Delhi08 Aug 2023AY 2009-10

Bench: Or At The Time Of Hearing Of The Appeal.”

Section 139Section 143(3)Section 148Section 153CSection 68

creditor and genuineness of the transaction in compliance with Section 68 of the Act. The assessee company by self proclaiming itself as shell company cannot shirk and avoid its legal obligation to prove the identity and creditworthiness of the so called share applicants and genuineness of the transaction as mentioned

Lokenath Investment Consultants P.Ltd, New Delhi vs. ACIT, Central Circle-8, New Delhi

In the result, the appeal of the assessee is dismissed

ITA 1097/DEL/2019[2009-10]Status: DisposedITAT Delhi31 Jul 2023AY 2009-10

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: NoneFor Respondent: Ms. Sarita Kumari, CIT DR

Section 139Section 148Section 153ASection 153C

application money u/s 68 of the Act without appreciating the fact the applicant company has no assets except paper entries showing investment in other shell companies. The appellant has contended that if these were actual assets in these shell companies then these would have been taken over by the Priya ... identity and creditworthiness of the so called share applicants and genuineness of the transactions. The appellant just contended that the appellant company is a shell company. It has no assets except paper entries showing investment in other shell companies. In fact if there were actual assets in these shell companies

Jayton Trading Pvt. Ltd., Kolkata vs. Dy. Commissioner of Income Tax (Central)-2, Raipur

In the result, appeal of the assessee is allowed

ITA 65/RPR/2021[2012-13]Status: DisposedITAT Raipur31 Jul 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.65/Rpr/2021 (Assessment Year: 2012-2013) Jayton Trading Private Limited, Vs Dcit (Central)-2, Raipur 15, Crooked Lane, 1St Floor, Hare Street, Kolkata Pan No. :Aaacj 6659 B (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Jehangir D. Mistry, Sr. Advocate, Shri Madhur Agrawal, Advocate Shri Praveen Khandelwal & Praveen Goyal, Cas राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 29/05/2023 घोषणा क" तार"ख/Date Of Pronouncement : 31 /07/2023 आदेश / O R D E R Per Arun Khodpia, Am : The Assessee Has Filed This Appeal Against The Order Passed By The Cit(A)-3, Bhopal, Dated 06.07.2021 For The Assessment Year 2012-2013, On The Following Grounds :- 1. That On The Facts & In The Circumstances Of The Case & In Law, The Order Dated 06/07/2021 Passed U/S 250 Of The Act & The Assessment Order Passed U/S 144 R.W.S. 147 Of The Act Dated 30/12/2019 Are Illegal & Void Ab Initio. 2. That On The Facts & In The Circumstances Of The Case & In Law, The First Appellate Authority Erred In Not Confirming That The Notice Issued U/S 148 Of The Act Dated 28/03/2019 Is Bad In Law. 2.1 That On The Facts & In The Circumstances Of The Case & In Law, The First Appellate Authority Erred In Not Holding That The Notice Issued U/S 148 Of The Act Dated 28/03/2019 Is Time Barred By Limitation In View Of First Proviso To Section 147 Of The Act. 2.2 That On The Facts & In The Circumstances Of The Case & In Law, The First Appellate Authority Erred In Confirming The Reason Recorded U/S 148(2) Of The Act Though The Same Is Only A Change Of Opinion On Account Of Borrowed Satisfaction Without Application Of Mind By The Assessing Officer.

For Appellant: Shri Jehangir D. Mistry, Sr. AdvocateFor Respondent: Smt. Ila M. Parmar, CIT-DR

Section 143(3)Section 144Section 147Section 148Section 148(2)Section 250Section 68

capital and share premium. The AO found that the share capital and premium had been received by the assessee company from the Kolkata based shell company of Rs.10,70,75,000/-, which has been incorporated by the AO in the assessment order at page 2. Accordingly, the case was reopened ... recorded might be different but the intent of the revenue was the same that bogus share capital/ premium and unsecured loans through Kolkata based shell companies were transacted therefore, the same should be brought within the ambit of tax net, hence the same needs to be added to the income

Shri Darshan K Vakharia, Mumbai vs. Income Tax Officer, Ward 2(1), Mumbai

Appeal is allowed

ITA 1540/MUM/2023[2012-2013]Status: DisposedITAT Mumbai28 Jul 2023AY 2012-2013

Bench: Shri Br Baskaran, Am & Shri N. K. Choudhry, Jm आयकरअपीलसं./ I.T.A. No. 1540/Mum/2023 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं./I.T.A. No. 1539/Mum/2023 (निर्धारणवर्ा / Assessment Year: 2013-14)

For Appellant: Shri. Vimal PunmiyaFor Respondent: Shri. Nagnath B. Pasale

Section 132Section 132(4)Section 147Section 250

provisions of section 147 of the Act by the AO after it was found that the appellant had received accommodation entries from a shell company. The AO had cogent material in the form of information/material gathered by the department at the time of search and seizure operation on Mr. Vipul ... hence no addition could be made, is not acceptable. The appellant has paid the interest on the loan to the two entities, which were shell companies providing accommodation entries to various parties (one of the beneficiary was the appellant) as admitted by their director/operator. The appellant has provided the copies

Shri Darshan K Vakharia, Mumbai vs. Income Tax Officer, Ward 2(1), Mumbai

Appeal is allowed

ITA 1539/MUM/2023[2013-2014]Status: DisposedITAT Mumbai28 Jul 2023AY 2013-2014

For Appellant: Shri. Vimal PunmiyaFor Respondent: Shri. Nagnath B. Pasale

Section 132Section 132(4)Section 147Section 250

Divyaben Prafulchandra Parmar, Surat vs. Income Tax Officer, Ward 1(3)(1), Surat

In the result, appeal filed by the assessee is allowed

ITA 73/SRT/2023[2014-15]Status: DisposedITAT Surat27 Jul 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.73/Srt/2023 (Assessment Year: 2014-15) (Physical Hearing) Divyaben Prafulchand Parmar, Vs. The Ito, Ward-1(3)(1), 1-2, Harikrishna Niwas, B/H Braham Surat. Kumari Ashram, Bhatar Road, Surat – 395017. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acbpp9559Q (Appellant) (Respondent)

Section 115BSection 143(3)Section 68Section 69

case of Jagat Pravinbhai Sarabhai, [2022] 142 taxmann.com 247, held that where Assessing Officer noted that assessee had indulged in scrip of shell company and had claimed long term capital gain on sale of shares and made addition under section 68 holding that entire transaction was bogus ... declaring his total income Rs. 3,11,490/-. Subsequently the assessment was reopened as information was received that assessee has indulged into script of shell company and had claimed long term capital gain on sale of shares of Devika Proteins Limited to the tune

Spectrum Infonet Pvt. Ltd., Raigarh vs. Pr. Commissioner of Income Tax (Central), Bhopal

In the result, appeal filed by the assessee in ITA No

ITA 34/RPR/2022[2011-12]Status: DisposedITAT Raipur14 Jul 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 33 & 34/Rpr/2022 "नधा"रण वष" / Assessment Years : 2010-11 & 2011-12 Spectrum Infonet Private Limited 601, South Gajanandpuram Colony, Kotra Road, Raigarh (C.G.)-496001 Pan : Aalcs5656E .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax (Central), Bhopal ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR

Section 147Section 263

database of Kolkata Investigation wings, it is revealed that M/s Cherry Vintrade Pvt. Ltd. (vide SL No.10608 is an identified paper bogus shell company having director Shri Ashis Kumar(PAN-ANMPK1331K) and Shri Rahul Sharma (PAN-AWSPS8620A) are dummy directors under the control and management by identified entry operator Shri