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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

Eager Corporation, Mumbai vs. DCIT-Cent-Cir 8(3), Mumbai

In the result, the appeals filed by the assessee are allowed

ITA 5258/MUM/2024[A.Y 2012-13]Status: DisposedITAT Mumbai12 Feb 2026

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 132Section 144Section 153A

anterior to the search proceedings. (III) Whether the Assessing Officer was justified in making additions primarily relying upon statements recorded from third parties, alleged entry operators, and findings of the Investigation Wing without establishing any direct nexus between seized material and the impugned additions in the hands of the assessee

Eager Corporation, Mumbai vs. DCIT-Cent-Cir 8(3), Mumbai

In the result, the appeals filed by the assessee are allowed

ITA 5221/MUM/2024[A.Y 2010-11]Status: DisposedITAT Mumbai12 Feb 2026

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 132Section 144Section 153A

anterior to the search proceedings. (III) Whether the Assessing Officer was justified in making additions primarily relying upon statements recorded from third parties, alleged entry operators, and findings of the Investigation Wing without establishing any direct nexus between seized material and the impugned additions in the hands of the assessee

Eager Corporation, Mumbai vs. DCIT-Cent-Cir 8(3), Mumbai

In the result, the appeals filed by the assessee are allowed

ITA 5220/MUM/2024[A.Y 2011-12]Status: DisposedITAT Mumbai12 Feb 2026

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 132Section 144Section 153A

anterior to the search proceedings. (III) Whether the Assessing Officer was justified in making additions primarily relying upon statements recorded from third parties, alleged entry operators, and findings of the Investigation Wing without establishing any direct nexus between seized material and the impugned additions in the hands of the assessee

ACIT Circle-12, Pune vs. Dhiraj Bhausaheb Nikam, Pune

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 1375/PUN/2025[2014-15]Status: DisposedITAT Pune11 Feb 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15 Acit, Circle – 12, Pune Dhiraj Bhausaheb Nikam Vs. 515/516, Purva Plaza, Sadashiv Peth, Pune – 411030 Pan: Aahpn5137C (Appellant) (Respondent) Assessee By : None Department By : Shri Deepak Kumar Kedia, Jcit (Through Virtual) Date Of Hearing : 10-02-2026 Date Of Pronouncement : 11-02-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: NoneFor Respondent: Shri Deepak Kumar Kedia, JCIT
Section 10(38)Section 142(1)Section 143(2)Section 2(47)

Mountain View Developers Pvt Ltd on 03.12.2016 but no response was received from the said party. The Assessing Officer also conducted enquiries on entry operators / share broker/sub- brokers and also went through the data received from the investigation wing in the ITS window in the ITD system of the department ... Assessing Officer further noted that during the course of enquiries by the investigation wing it has been admitted by a number of entry operators and share broker/sub-brokers that the share prices of M/s. Anukaran Commercial Enterprises Ltd has been jagged up through cartel of interlinked companies controlled and managed

Meghji Mansukhlal Dodhia, Bhiwandi vs. DCIT-CC-3, Thane

ITA 2224/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. It(Ss)A No. 2226/Mum/2025 S.A. No. 79/Mum/2025 (Assessment Year: 2012-13) Mansukhlal Meghji Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) Dcit Cc-3, Thane Vs. Room No. 12, A Wing, 6Th Floor, Ashar It Park, Thane, West, Maharashtra - 400 604 Pan/Gir No. Aaspd6746L (Respondent) 2. Ita No. 2224/Mum/2025 S.A. No. 80/Mum/2025 (Assessment Year: 2013-14) 3. It(Ss)A No. 2223/Mum/2025 S.A. No. 81/Mum/2025 & 4. It(Ss)A No. 2222/Mum/2025 S.A. No. 82/Mum/2025 (Assessment Year: 2015-16) 5. It(Ss)A No. 2225/Mum/2025 S.A. No. 83/Mum/2025 (Assessment Year: 2016-17) Meghji Mansukhlal Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) Dcit Cc-3, Thane Vs. Room No. 12, A Wing, 6Th Floor, Ashar It Park, Thane, West, Maharashtra - 400 604 Pan/Gir No. Aaspd6746L (Respondent) (2) It(Ss)A No. 2226, 2223, 2222 & 2225/Mum/2025 &

Section 132Section 143(3)Section 153ASection 68Section 69D

Vinam Finance Private Limited has been made solely on the basis of statements recorded by the Investigation Wing from Shri Sushil Goyal, an alleged entry operator, certain alleged dummy directors namely Shri Bhavik Jakharia and Shri Minesh Dodhia, and Shri Bhadresh Dodhia. It was contended that the Assessing Officer

Income Tax Officer, Ward-1(1), New Delhi vs. Adonia Systems Private Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 835/DEL/2025[2019-20]Status: DisposedITAT Delhi11 Feb 2026AY 2019-20

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.835/धिल्ली/2025(नि.व. 2019-20) Income Tax Officer, Ward-1(1), R. No.199F, Central Revenue Building, ...... अपीलार्थी/Appellant I.P Estate, Delhi 110002 बिाम Vs. Adonia Systems P. Ltd., Bn-5, West Shalimar Bagh, Delhi 110088 .....प्रनिवादी/Respondent Pan: Aakca-8790-Q अपीलार्थी द्वारा/ Appellant By: Shri Om Prakash, Sr. Dr प्रधििािीद्वारा/Respondent By: S/Shri Manoj Kumar Aggarwal & Rahul Gaur, Chartered Accountants सुिवाई की निथर्थ/ Date Of Hearing : 03/02/2026 घोषणा की निथर्थ/ Date Of Pronouncement : 03/02/2026 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Om Prakash, Sr. DRFor Respondent: S/Shri Manoj Kumar Aggarwal & Rahul Gaur
Section 148ASection 68Section 69C

addition of Rs.5,64,767/- u/s.69C of the Act allegedly being unexplained expenditure (payment of commission) for obtaining bogus entry of loan from entry operator. 3. Shri Om Prakash, representing the department vehemently defending the assessment order dated 19.02.2024 submitted that a search and seizure operation was conducted on Ankit ... Bhageria on 01.09.2021 in the case Filatex Group. Shri Ankit Bhageria is an entry operator. During the course of search, it was found that Ankit Bhageria was providing accommodation entries against cash through its several shell entities. The assessee was one of the beneficiaries. The assessee during assessment proceeding

Gulmohar Towers Private Limited, Kolkata vs. Income Tax Officer, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 976/KOL/2025[2011-12]Status: DisposedITAT Kolkata10 Feb 2026AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S. Jhajharia, ARFor Respondent: Shri P.N. Barnwal, DR
Section 143(1)Section 147Section 148Section 148(2)

from sale of shares/ investments amounting to %43,32,00,000, which according to the Id. AO was arranged by Shri Anand Sharma an entry operator. 3.2. In the appellate proceedings, the Id. CIT (A) restored the issue to the file of the Id. AO without deciding the legal ... received fund worth Rs.43,32,00,000/- from various paper/shell companies managed and controlled by Shri Anand Sharma, who happened to be an entry operator engaged in the business of providing accommodation entries of bogus share capital etc. As a result of investigation, it has been emerged that Shri Anand

DCIT - 19(1), Mumbai, Lalbaugh vs. Bharat Ramji Bhai Manek, Grant Road Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 4339/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Feb 2026AY 2014-15

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ronak DoshiFor Respondent: Shri Leyaqat Ali Aafaqui, (SR DR)
Section 10(38)Section 143(3)Section 250

picture painted by the Investigation Wing. The detailed modus operandi-preferential allotment, price rigging through circular trading, use of exit providers, and statements of entry operators like Shri Raj Kumar Kedia and Shri Anil Agarwal establishes a pre-meditated scheme. The assessee's transaction fits perfectly into this pattern ... establish the assessee’s involvement in the alleged accommodation entry scheme or to demonstrate a live nexus between the assessee and the so-called entry operators. Mere reliance on general investigation reports, statements of third parties, or abnormal price movement of the scrip, without any direct evidence linking the assessee

DCIT, Central Circle 7(1), Mumbai vs. Dr D Y Patil Educational Academy, Mumbai

In the result, the appeal filed by the revenue stands

ITA 3922/MUM/2025[2015]Status: DisposedITAT Mumbai10 Feb 2026

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 132Section 147Section 153CSection 250Section 68

Sodhani, Mr. Kirit Dharshibhai Suba is the Auditor of Podar Group and Mr. Jayesh Zanani is the Manager Accounts. Further, the statement of entry operator Mr. Shirish Shah was recorded and Mr. Dhirubhai Thakkar and Mr. Sureshbhai Thakkar of Dhara Angadia Services, Ahmadabad were recorded. Based on these statements, learned ... were the persons on behalf of whom they used to transfer money. vi. Statement of Mr. Shirish Shah, who is alleged to be an entry operator, stated that in four companies he was to introduce share capital of Podar group. vii. During search proceedings, statement of Mr. Jayesh Zanani

Krishan Pal, Gurgaon vs. ITO, Ward 2(2)-Gurgaon, Gurgaon

Appeal is allowed

ITA 139/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 139/Del/2026 : Asstt. Year: 2014-15 Krishan Pal, Vs Income Tax Officer, C/O Ca M R Sahu, Ward-2(2), House No. 651, 1St Floor, Sector- Gurgaon, 10A, Near G. D. Goenka Public Haryana-22001 School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Asqpk6236J Assessee By: Sh. M. R. Sahu, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1068016367(1) Dated 27.08.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 142(1)Section 147Section 148Section 151ASection 80C

investigation in the case of M/s. Darsh Coke Trading Pvt. Ltd., it was revealed that the said company is a paper company through which entry operators provide bogus entries and layer money in exchange of commission. It was also found that the one of the beneficiaries is the assessee company

Deputy Commissioner of Income Tax, Central Circle-3(3), Kolkata vs. Adhunik Infrastructures Private Limited, Kolkata

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

ITA 1069/KOL/2024[2015-16]Status: DisposedITAT Kolkata09 Feb 2026AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 131Section 131(1)Section 143(3)Section 148Section 250Section 68Section 69A

allegation against the assessee company in the said statement. There is no evidence brought on record by the assessing officer to connect the said entry operator with the loan transaction ITA No.: 1069/KOL/2024 Assessment Year: 2015-16 Adhunik Infrastructures Private Limited. done by the assessee. Therefore, the statement

Amiben Rajeshkumar Punatar, Rajkot vs. ITO, Ward-1(2)(1), Rajkot

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

ITA 24/RJT/2026[2015-16]Status: DisposedITAT Rajkot06 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.24/Rjt/2026 िनधा"रण वष"/Assessment Year : 2015-16 Amiben Rajeshkumar Punatar, बनाम/ Ito, Ashish, 41-New Jagnath Plot, Vs Ward – 1(2)(1), Rajkot – 360001(Gujarat) Rajkot "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahrpp4181F (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 10(38)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 250

same has been used for booking bogus claims of Long-Term Capital gains or Short-Term Capital loss by Various beneficiaries. Further, the entry operators are charging @ 3 to 5% in Cash on net pre-arranged bogus LTCG or STCL. On going through the case records as well as return

ACIT19(3), Mumbai vs. Yogeshkumar Pravinkumar Shah, Mumbai

ITA 6163/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Feb 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Respondent: Revenue by
Section 143(3)

findings of investigation wing, the AO in the assessment order did not record anything that links the assessee to the exit providers or entry operators or the assessee's involvement in price rigging. It is also relevant to notice that the assessee during the year under consideration has sold other

Amit Anand, Delhi vs. ITO Ward-36(1), Delhi

ITA 3980/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri Krinwant Sahayasstt. Year : 2016-17

For Appellant: Shri Rakesh Jain, Adv. & CA Gupreet SinghFor Respondent: Shri Manish Gupta, Sr. DR
Section 145Section 147Section 44ASection 69A

Vijay Kumar Jain on account of unexplained money u/s. 69A of the Act. In appeal, Ld. CIT(A) noted that the entity operated by entry operator are shell entity and a façade to provide accommodation entry. Shri Vijay Kumar Jain had admitted that he had not done any business transaction

DCIT, Vikash Bhawan Delhi vs. Rajan Kumar, Laxmi Nagar, Delhi

In the result, the appeal of the Revenue appeal is dismissed and the cross objection filed by the assessee is allowed in the aforesaid manner

ITA 130/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Sudhir Kumar & Smt. Renu Jauhridcit Vs Rajan Kumar Room No. 218-D Block, 31,Vijay Block Laxmi Vikash Bhawan, Nagar Delhi-110092 Delhi- 110 002 Pan: Caapk8381E

Section 132Section 142(1)Section 143(1)Section 147Section 148Section 69A

arises. On the other hand in pars 12 of the assessment order, the AO observed that the conduct of the appellant seems to like entry operator. If the perception of the AO is true then also the entire amount can not be added to the income of the appellant

ACIT, New Delhi vs. Sparsh Property Private Limited, Delhi

In the result, the Revenue’s appeal as well as Assessee’s cross objection stand dismissed

ITA 5849/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri Krinwant Sahayacit, Vs. M/S Sparsh Property Room No. 261-A, 2Nd Floor, Private Limited, E-2, Jhandewalan Extn., 43, Community Center, New Delhi – 110 055 New Friends Colony, S.O. Zakir Nagar, South East Delhi, New Delhi – 110 025 (Pan: Aabcs8660C) (Appellant) (Respondent) C.O. No. 56/Del/2025 (Ita No. 5849/Del/2024) (Ay 2016-17)

For Appellant: Sh. Biren Shah, CA & Sh. Rohit Aggarwal, CAFor Respondent: Sh. Mahesh Kumar, CIT(DR)
Section 132Section 143(1)Section 148Section 68

illegal operations. He further submitted that Ld. CIT(A) also failed to appreciate that submissions of audited accounts and bank statements of alleged entry operator are necessary prerequisite to give such entities a semblance of a genuine business and also failed to appreciate that accommodation entry operators have sufficient funds ... conduct of any audit / investigation by SEBI/RBI , while the search conducted by Investigation Wing brought out substantial evidence about actual financial conduct of these entry operators, masquerading in the guise of NBFC. In view of above, he submitted that the addition made

ACIT, New Delhi vs. Nouvelle Securities Pvt Ltd, Delhi

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

ITA 4852/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Manoj Tiwari, Sr. DR
Section 132Section 132(4)Section 153ASection 37Section 68Section 69C

hide its illegal operations. 3. The Ld' CIT(A) has failed to appreciate that submissions of audited accounts and bank statements of alleged entry operator are necessary Page 2 of 12 CO No. 21/DEL/2025 [A.Y. 2016-17] Nouvelle Securities pre-requisite to give such entities a semblance of a genuine ... Filing of such documents does not mitigate lack of genuineness in its actual operations. 4. Ld. CIT(A) has failed to appreciate that accommodation entry operators have sufficient funds only in the form of investments in other non-genuine companies. There is hardly substantial balance in the bank account

Income Tax Officer, Aaykar Bhawan vs. Shiv Shankar Rice Mills, Gogripur Road

In the result, the appeal of the Revenue is dismissed

ITA 4630/DEL/2024[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2013-14]

Section 143(3)Section 147Section 148Section 151

made it can only be sustained on the gross profit margin of the net sales (i.e., sales - purchases alleged to be from an entry operator). The e addition of the total amount is bad in law and liable to set aside. 5.8 Considering the above facts and submission

DCIT, Central Circle-4(3), Kolkata vs. Raj Goenka, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1801/KOL/2025[2022-23]Status: DisposedITAT Kolkata05 Feb 2026AY 2022-23

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2022-23 Dcit, Cc-4(3), Kolkata……...……..……….………….……….……….……Appellant Vs. Raj Goenka…………………………………………..…….....……...…..…..Respondent 10Th Floor Magma House, 24, Park Street Park Street, Kol-16. [Pan: Adlpg8181C] Appearances By: Shri S B Chakraborthy, Addl. Cit, Appeared On Behalf Of The Appellant. Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : February 05, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 12.04.2025 Of The Cit(Appeals)-27, Kolkata (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2022–23. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 08 Days. The Revenue Has Filed A Petition For Condonation Of The Delay. After Considering The Reasons Cited In The Petition For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 127Section 132(1)Section 139Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

allegation against the assessee company in the said statement. There is no evidence brought on record by the Assessing Officer to connect the said entry operator with the loan transaction done by the assessee. Therefore, the statement is of little avail and could not have been the basis for making

Mukesh Agarwal, Rourkela vs. Income Tax Office, Ward 1, Rourkela

Appeal of the assessee is allowed

ITA 631/CTK/2025[2015-16]Status: DisposedITAT Cuttack04 Feb 2026AY 2015-16

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuआयकर अपील सं/Ita No.631/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2015-2016) Mukesh Agarwal, Vs Ito Ward-1, Rourkela O-18, Civil Township, Rourkela-769004 Pan No. : Adipa 0575 D (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Ayush Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 04/02/2026 घोषणा की तारीख/Date Of Pronouncement : 04/02/2026 आदेश / O R D E R Per George Mathan, Jm :

For Appellant: Shri Ayush Agarwal, ARFor Respondent: Shri Vijay Singh, Sr. DR
Section 10(38)

through whom the assessee sold the shares of KAFL as a beneficiary to the alleged accommodation entries provided by the related entities / promoters / brokers / entry operators. In the instant case, the shares of CPAL were purchased by the assessee way back on 20.12.2011 and pursuant to merger of CPAL with