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“entry operator”

Cash Credits & Unexplained ItemsSection 68Section 682,071 judgments

The decision most relied on for entry operator is CIT v. Jamnadevi Agarwal (328 ITR 656), cited in 230 judgments on BharatTax.

Leading authorities on entry operator

CIT v. Jamnadevi Agarwal
328 ITR 656 · 2010 · High Court
230
citing judgments

When faced with allegations of bogus long-term capital gains from penny stocks, the Assessing Officer must discharge the onus of proving that the assessee's transactions were not genuine. The assessee can rely on the principle of preponderance of probability, and the Revenue must present substantial evidence to establish that the transactions were a colourable device or that the assessee was an entry operator.

ITO, 19(3) (4) Mumbai v. Shamim M Bharwani
69 Taxmann.com 65 · 2016 · Reported
142
citing judgments

Long Term Capital Gains (LTCG) from penny stock transactions are liable to be treated as bogus and added back under Section 68 as unexplained cash credits, especially when evidence suggests the involvement of entry operators providing accommodation entries.

5. PCIT v. Paramount Communication (P.) Ltd. Delhi High Court
392 ITR 444 · 2017 · High Court
111
citing judgments

For valid initiation of reassessment proceedings, the Assessing Officer must possess tangible material and apply independent mind to form a 'reason to believe' that income has escaped assessment. Reassessment cannot be based on mere borrowed satisfaction or unverified information without proper scrutiny.

2 CIT v. Indrajit Singh Suri
33 Taxmann.com 281 · 2013 · High Court
100
citing judgments

The validity of reassessment proceedings initiated under Sections 147/148 against legal representatives of a deceased assessee requires a demonstrable 'reason to believe' that income escaped assessment, often based on third-party information such as alleged accommodation entries.

Dharappa v. Bijapur Co-operative Milk Producers Societies Union Ltd.
9 SCC 109 · 2007 · Reported
62
citing judgments

When a State Act has obtained presidential assent, its repugnant provisions prevail over the provisions of a Central Act in that State, even if both laws relate to subjects in the Concurrent List. This principle was applied to determine repugnancy between the Karnataka Co-operative Societies Act, 1959, and the Industrial Disputes Act, 1947.

CIT v. Sanghamitra Bharali
361 ITR 481 · 2014 · High Court
60
citing judgments

Capital gains arising from sham transactions, particularly those involving penny stocks designed to appear genuine, are not exempt under Section 10(38) but are taxable as unaccounted income brought into the books.

CIT v. Active Traders (P.) Ltd.
214 ITR 583 · 1995 · High Court
55
citing judgments

When a sum is credited on account of share capital or share premium, the assessee must establish the existence, identity, genuineness, and creditworthiness of the share applicants, going beyond mere submission of documents. The Assessing Officer has the power to investigate and lift the corporate veil to ascertain the bonafides of such transactions.

Income Tax Vs. India Discount Co. Ltd. 75 ITR 191 (SC), Commissioner of Income Tax v. Provincial Farmers (P) Ltd.
245 ITR 421 · 2000 · Supreme Court
55
citing judgments

The entry in the books of accounts is not determinative of the true nature of a transaction for income tax purposes; the substance of the transaction, rather than its accounting treatment, governs its taxability and deductibility.

Judgments citing entry operator

Assistant Commissioner of Income Tax, Jalgaon vs. Sidharth Ratanlal Bafna, Jalgaon

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1555/PUN/2024[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Respondent: S/Shri Suchek Anchaliya and
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

Kuntala Mohapatra (2024) 160 taxmann.com 608 (SC). In that case, the assessing officer made additions undersections 68 and 69 by relying on statements from 'entry operators', by rejectingthe assessee's revised return claiming exemption under section 10(38) for long-term capital gains. On appeal, Commissioner (Appeals) accepted assessee ... after payment of security transaction tax. On further appeal, Tribunal upheld CIT(A)'s decision, criticizing the assessing officer's reliance on statements from 'entry operators' to support additions under sections 68 and 69 as those statements were recorded in unrelated proceedings before survey on assessee. On revenue's appeal

DCIT, CC-2(1), Kolkata vs. Amanat Trade Comm Pvt Ltd, Kolkata

In the result, all the captioned appeals of the revenue are dismissed

ITA 1311/KOL/2025[2012-13]Status: DisposedITAT Kolkata27 Oct 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1290, 1307 & 1308/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Frankdeal Tradcom Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aabcf1099A] Ita Nos.1309, 1310 & 1311/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Amanat Trade Comm Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aagca3278H] Appearances By: Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2010-11, 2011-12 & 2012-13 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-26, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Search Operation, Therefore, These Appeals Have Been Heard Together & Are

Section 132Section 139(1)Section 143(1)Section 143(2)Section 153ASection 250Section 68Section 69C

erred in ignoring the addition on the basis of document marked as BGHO/9 seized during the course of search and statement of the accommodation entry operator during the search operation and mainly relied on the other documents in the course of search. ITA Nos.1290, 1307 & 1308/Kol/2025 Frankdeal Tradcom

DCIT, CC-2(1), Kolkata vs. Amanat Trade Comm Pvt Ltd, Kolkata

In the result, all the captioned appeals of the revenue are dismissed

ITA 1310/KOL/2025[2011-12]Status: DisposedITAT Kolkata27 Oct 2025AY 2011-12

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1290, 1307 & 1308/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Frankdeal Tradcom Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aabcf1099A] Ita Nos.1309, 1310 & 1311/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Amanat Trade Comm Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aagca3278H] Appearances By: Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2010-11, 2011-12 & 2012-13 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-26, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Search Operation, Therefore, These Appeals Have Been Heard Together & Are

Section 132Section 139(1)Section 143(1)Section 143(2)Section 153ASection 250Section 68Section 69C

erred in ignoring the addition on the basis of document marked as BGHO/9 seized during the course of search and statement of the accommodation entry operator during the search operation and mainly relied on the other documents in the course of search. ITA Nos.1290, 1307 & 1308/Kol/2025 Frankdeal Tradcom

DCIT, CC -2(1), Kolkata vs. Amanat Trade Comm Pvt Ltd, Kolkata

In the result, all the captioned appeals of the revenue are dismissed

ITA 1309/KOL/2025[2010-11]Status: DisposedITAT Kolkata27 Oct 2025AY 2010-11

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1290, 1307 & 1308/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Frankdeal Tradcom Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aabcf1099A] Ita Nos.1309, 1310 & 1311/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Amanat Trade Comm Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aagca3278H] Appearances By: Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2010-11, 2011-12 & 2012-13 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-26, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Search Operation, Therefore, These Appeals Have Been Heard Together & Are

Section 132Section 139(1)Section 143(1)Section 143(2)Section 153ASection 250Section 68Section 69C

erred in ignoring the addition on the basis of document marked as BGHO/9 seized during the course of search and statement of the accommodation entry operator during the search operation and mainly relied on the other documents in the course of search. ITA Nos.1290, 1307 & 1308/Kol/2025 Frankdeal Tradcom

DCIT, CC-2(1), Kolkata vs. Frankdeal Tracom Pvt Ltd, Kolkata

In the result, all the captioned appeals of the revenue are dismissed

ITA 1308/KOL/2025[2012-13]Status: DisposedITAT Kolkata27 Oct 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1290, 1307 & 1308/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Frankdeal Tradcom Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aabcf1099A] Ita Nos.1309, 1310 & 1311/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Amanat Trade Comm Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aagca3278H] Appearances By: Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2010-11, 2011-12 & 2012-13 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-26, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Search Operation, Therefore, These Appeals Have Been Heard Together & Are

Section 132Section 139(1)Section 143(1)Section 143(2)Section 153ASection 250Section 68Section 69C

erred in ignoring the addition on the basis of document marked as BGHO/9 seized during the course of search and statement of the accommodation entry operator during the search operation and mainly relied on the other documents in the course of search. ITA Nos.1290, 1307 & 1308/Kol/2025 Frankdeal Tradcom

DCIT, CC-2(1), Kolkata vs. Frankdeal Tracom Pvt. Ltd., Kolkata

In the result, all the captioned appeals of the revenue are dismissed

ITA 1307/KOL/2025[2011-12]Status: DisposedITAT Kolkata27 Oct 2025AY 2011-12

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1290, 1307 & 1308/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Frankdeal Tradcom Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aabcf1099A] Ita Nos.1309, 1310 & 1311/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Amanat Trade Comm Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aagca3278H] Appearances By: Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2010-11, 2011-12 & 2012-13 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-26, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Search Operation, Therefore, These Appeals Have Been Heard Together & Are

Section 132Section 139(1)Section 143(1)Section 143(2)Section 153ASection 250Section 68Section 69C

erred in ignoring the addition on the basis of document marked as BGHO/9 seized during the course of search and statement of the accommodation entry operator during the search operation and mainly relied on the other documents in the course of search. ITA Nos.1290, 1307 & 1308/Kol/2025 Frankdeal Tradcom

DCIT, CC-2(1), Kolkata vs. Frankdeal Tracom Pvt Ltd, Kolkata

In the result, all the captioned appeals of the revenue are dismissed

ITA 1290/KOL/2025[2010-11]Status: DisposedITAT Kolkata27 Oct 2025AY 2010-11

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1290, 1307 & 1308/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Frankdeal Tradcom Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aabcf1099A] Ita Nos.1309, 1310 & 1311/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Amanat Trade Comm Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aagca3278H] Appearances By: Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2010-11, 2011-12 & 2012-13 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-26, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Search Operation, Therefore, These Appeals Have Been Heard Together & Are

Section 132Section 139(1)Section 143(1)Section 143(2)Section 153ASection 250Section 68Section 69C

erred in ignoring the addition on the basis of document marked as BGHO/9 seized during the course of search and statement of the accommodation entry operator during the search operation and mainly relied on the other documents in the course of search. ITA Nos.1290, 1307 & 1308/Kol/2025 Frankdeal Tradcom

Pramod Lakra, Deputy Commissioner of Income Tax, Circle 11(1), Kolkata vs. M/S. Dalmia Impex Private Limited, Kolkata

In the result the Cross Objection No

ITA 2544/KOL/2024[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 143(3)Section 148Section 148A

loss of ₹1,36,14,400/-. The said entity was identified as a paper company controlled by one Shri Pankaj Agarwal, a known entry operator. The Assessing Officer, being unsatisfied with the explanation of the assessee, treated the loss as bogus and further made an addition

Anjali Gupta, Gurgaon vs. ITO Ward -1(2), Gurgaon

In the result, appeal of the assessee is allowed

ITA 3605/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Oct 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Ms. Anjali Gupta, Ito, Ward-1(2), A-84, Summit, Dlf City-5, Gurgaon, Sector-56, Gurgaon, Vs Haryana Pan-Aaipg5132F Appellant Respondent Assessee By Shri Vijay Kumar Singla, Ca Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.07.2025 Date Of Pronouncement 27.10.2025

Section 10(38)Section 115BSection 143(3)Section 68

scrupulous activities or directly linked to one of the person who has 25 ITA No.5418/DEL/2018 ITA No.2531/Del/2022 involved in manipulation/rigging of share prices, entry operator or exit provider as observed by the Hon’ble Bombay High Court in the case of Ziauddin A Siddique (supra). Therefore, there is no material

DCIT-2(2)(1), Mumbai vs. Jyoti Structures Limited, Mumbai

In the result, appeal of the revenue is dismissed

ITA 4825/MUM/2025[2007-08]Status: DisposedITAT Mumbai24 Oct 2025AY 2007-08

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Madhur Agrawal, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 153A

Ld.CIT(A) was justified in arbitrarily estimating commission expenditure at 1% without appreciating that the AO had relied on sworn statement of entry operator who admitted to charging 2% commission for bogus transactions? I.T.A. No. 4825/Mum/2025 2 4. Whether on the facts and in the circumstances of the case

Kailash Gahlot, New Delhi vs. DCIT, Central Circle-4, New Delhi

In the result, the appeal of the assessee is partly allowed as above

ITA 3431/DEL/2023[2015-16]Status: DisposedITAT Delhi24 Oct 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.3431/Del./2023, A.Y. 2015-16 Kailash Gahlot Deputy Commissioner Of C-6/6172, Vasant Kunj, Income Tax, New Delhi Vs. Central Circle-4, Pan: Aajpg2849N New Delhi (Appellant) (Respondent) Appellant By Sh. Vinod Kumar Bindal, Ca Sh. Anmol Jha, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 24/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2015-16 Is Directed Against The Order Dated 30.09.2023 Of The Commissioner Of Income Tax (Appeals)-23, New Delhi [‘Cit(A)’].

Section 115BSection 132(4)Section 153DSection 69C

Stock Brokers Pvt. Ltd. (ITA No. 544/2005, 134/2014 & CM Appl. No. 5666/2014 order dated 12.09.2018) and various orders of Tribunal in cases of entry operators, where the Tribunal has upheld commission income in the hands of entry operators and unexplained credits in the hands of real beneficiaries

ACIT, New Delhi vs. Sh. Anil Aggarwal, Ghaziabad

In the result, the appeal of the revenue is dismissed

ITA 1137/DEL/2016[2008-09]Status: DisposedITAT Delhi24 Oct 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2008-09] Asstt. Commissioner Of Sh. Anil Aggarwal, Income Tax, H. No. 67, Sector-1, Vaishali, Central Circle-06, Vs Ghaziabad, Up. New Delhi. Pan- Afgpa3349M Revenue Assessee

Section 132Section 153A

well as at the residential premises of directors of the companies on 06/09/2011. A consequential search action was conducted on Sh. Anil Aggarwal, an entry operator based in Laxmi Nagar, New-Delhi, on 21/10/2011. Thereafter, notice under section 153A of the IT Act, 1961 was issued on 14/02/2014. In response

Yogeshkumar Pravinkumar Shah, Mumbai vs. Asstt. Commissioner of Income Tax 19(3), Mumbai

ITA 4544/MUM/2025[2014-2015]Status: DisposedITAT Mumbai22 Oct 2025AY 2014-2015

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri K. Gopal & Om KandalkarFor Respondent: 16.09.2025
Section 10(38)Section 148Section 250Section 68

significantly by exploiting the orchestrated scam uncovered by the department. Given that M/s Sunrise Asian Ltd was utilized to provide accommodation entries by the entry operator Shri Vipul Vidhur Bhat, and the shares were artificially manipulated with the intent to provide bogus long- term capital gains (LTCG), and the appellant ... mentions a company name M/s. Monarch Health Services Ltd and its director without recording any finding regarding the assessee's connection with the brokers / entry operator. We in this regard further notice that the Co-ordinate Bench has considered the identical issue in the case of Lalitaben Pravin Shah (supra

Stercon Energy Pvt. Ltd., Delhi vs. ACIT, Central Circle-29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5798/DEL/2024[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

Initiation of Proceedings  Notice u/s 153C was issued to the assessee company on 24.09.2019 consequent to search and seizure action in the case of entry operator Sh. Himanshu Verma.  In response, the assessee filed return declaring meagre income of Rs. 65,070/-. Subsequent notices ... basis of material gathered during search and submissions made, it was established that the assessee company was used by Sh. Himanshu Verma (entry operator) as a conduit company to provide bogus accommodation entries to beneficiaries.  The present shareholders/directors assumed control only from November 2015 onwards, prior thereto, the affairs were

Stercon Energy Pvt. Ltd., Delhi vs. ACIT Central Circle- 29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5797/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

Initiation of Proceedings  Notice u/s 153C was issued to the assessee company on 24.09.2019 consequent to search and seizure action in the case of entry operator Sh. Himanshu Verma.  In response, the assessee filed return declaring meagre income of Rs. 65,070/-. Subsequent notices ... basis of material gathered during search and submissions made, it was established that the assessee company was used by Sh. Himanshu Verma (entry operator) as a conduit company to provide bogus accommodation entries to beneficiaries.  The present shareholders/directors assumed control only from November 2015 onwards, prior thereto, the affairs were

Stercon Energy Pvt Ltd, Delhi vs. ACIT, Central Circle-29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5796/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

Initiation of Proceedings  Notice u/s 153C was issued to the assessee company on 24.09.2019 consequent to search and seizure action in the case of entry operator Sh. Himanshu Verma.  In response, the assessee filed return declaring meagre income of Rs. 65,070/-. Subsequent notices ... basis of material gathered during search and submissions made, it was established that the assessee company was used by Sh. Himanshu Verma (entry operator) as a conduit company to provide bogus accommodation entries to beneficiaries.  The present shareholders/directors assumed control only from November 2015 onwards, prior thereto, the affairs were

Raheja Developers Limited, New Delhi vs. DCIT, Central Circle 19, New Delhi

ITA 2284/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

ascertained by the DIT, Investigation Wing, Kolkata that 40 paper/shell companies were used by beneficiary companies for routing their own funds through known entry operators of Kolkata and M/s SagarTradelink Private Limited was one of such paper/shell company which was operated by entry operator namely Sh. Jagdish Prasad Purohit ... assessment proceedings u/s 143(3) of the Act the said Sagar Tradelink Private Limited was a paper company which was managed and controlled by entry operator namely Sh. Jagdish Prasad Purohit,who was engaged in providing accommodation entries to beneficiary entities through paper shell companies. On the receipt

Raheja Developers Limited, New Delhi vs. ACIT, Central Circle 19, Delhi

ITA 2283/DEL/2023[2011-12]Status: DisposedITAT Delhi17 Oct 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

ascertained by the DIT, Investigation Wing, Kolkata that 40 paper/shell companies were used by beneficiary companies for routing their own funds through known entry operators of Kolkata and M/s SagarTradelink Private Limited was one of such paper/shell company which was operated by entry operator namely Sh. Jagdish Prasad Purohit ... assessment proceedings u/s 143(3) of the Act the said Sagar Tradelink Private Limited was a paper company which was managed and controlled by entry operator namely Sh. Jagdish Prasad Purohit,who was engaged in providing accommodation entries to beneficiary entities through paper shell companies. On the receipt

Indian Ion Exchange & Chemicals Limited, Ahmedabad vs. The ITO, Ward-2(1)(1) Previously Ward-2(1)(3), Ahmedabad

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

ITA 1420/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2014-15

Section 143(3)Section 147Section 148

rival submissions. It transpired that the entire case of the Revenue is based on the statement of Shri Mahendra Shantilal Patel, the accommodation entry operator. The fact that the assessee had made purchase of Rs.92,20,100/- from M/s. Siddh Syndicate, which was operated by the said accommodation entry provider

Sneha Pawan Agarwal, Ahmedabad vs. ITO Ward 1(1)(3), Ahmedabad

The appeals are allowed for statistical purposes

ITA 1369/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2016-17

Bench: Ms. Suchitra Raghunath Kamble & Makarand V.Mahadeokar

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Veerabadram Vislavath, Sr.DR
Section 144Section 144BSection 147Section 250Section 253(3)Section 253(5)

basis of information received from the Investigation Wing, Ahmedabad, which had conducted search and verification in the cases of the Tibrewal (entry operator) group and unearthed large-scale accommodation entries in the names of various shell entities. 3.2 In both years, the Assessing Officer recorded reasons to believe that income