“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

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

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

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

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

DCIT, Central Circle 7(1), Mumbai vs. Supreme Holdings & Hospitality (India) Limited, Mumbai

In the result, all the appeals of the Revenue and Cross Objections by the assessee are dismissed

ITA 3978/MUM/2025[2014-15]Status: DisposedITAT Mumbai23 Jan 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 131Section 131(1)Section 132(1)Section 153ASection 68

given by the assessee company to accommodate any loan entry or there is any cash trail. Neither there is involvement of any kind of entry operator nor were these companies found to providing accommodation entry of loan by taking some temporary cash. Without such information or material, there cannot

DCIT, Central Circle 7(1), Mumbai vs. Supreme Holdings & Hospitality (India) Limited, Mumbai

In the result, all the appeals of the Revenue and Cross Objections by the assessee are dismissed

ITA 3977/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 131Section 131(1)Section 132(1)Section 153ASection 68

Mrs. Jigna Hiren Rambhia, Mumbai vs. ITO Ward 27(1)(5), Mumbai

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

ITA 5033/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Jan 2026AY 2014-15

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 10(38)Section 250Section 391Section 68

term capital 7 ITA No. 5033/Mum/2025; Jigna Hiren Rambhia, Mumbai gains. Nothing has been brought on record to show that the persons investigated, including entry operators or stock brokers, have named that the assessee was in collusion with them. Therefore in absence of such finding how is it possible

Income Tax Officer, Faridabad vs. Ramesh Kumar Bagri, Faridabad

ITA 524/DEL/2025[2016]Status: DisposedITAT Delhi21 Jan 2026

Bench: Shri S.Rifaur Rahman

For Appellant: REVENUE BYFor Respondent: Date of Hearing

Section 115BSection 139Section 142(1)Section 147Section 148Section 69

report was filed. 7. The AO has finally concluded that "on considering the above facts in totality, it appears that the assessee is an entry operator who provided bogus entry to various individuals/entities. Or providing entries, assessee has received commission from the beneficiaries. It can be said that credits amounting ... actual business whatsoever being carried out by the assessee. Hence, I agree with the view of the AO that the Assessee is merely an entry operator. PA Now, the AO, in his remand report has come to the conclusion that considering all the facts, and holding the assessee

Income Tax Officer, Faridabad vs. Ramesh Kumar Bagri, Faridabad

Accordingly, the appeal filed by the Revenue being ITA No.521/Del/2025 for AY 2015-16 is dismissed

ITA 523/DEL/2025[2013-14]Status: DisposedITAT Delhi21 Jan 2026AY 2013-14

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Akash Ojha, AdvocateFor Respondent: Ms. Pooja Swaroop, CIT DR

Section 115BSection 139Section 142(1)Section 147Section 148

Income Tax Officer, Faridabad vs. Ramesh Kumar Bagri, Faridabad

Accordingly, the appeal filed by the Revenue being ITA No.521/Del/2025 for AY 2015-16 is dismissed

ITA 522/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jan 2026AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Akash Ojha, AdvocateFor Respondent: Ms. Pooja Swaroop, CIT DR

Section 115BSection 139Section 142(1)Section 147Section 148Section 69

report was filed. - 7. The AO has finally concluded that "on considering the above facts in totality, it appears that the assessee is an entry operator who provided bogus entry to various individuals/entities. Or providing entries, assessee has received commission from the beneficiaries. It can be said that credits amounting ... actual business whatsoever being carried out by the assessee. Hence, I agree with the view of the AO that the Assessee is merely an entry operator. PA Now, the AO, in his remand report has come to the conclusion that considering all the facts, and holding the assessee

Income Tax Officer, Faridabad vs. Ramesh Kumar Bagri, Faridabad

ITA 521/DEL/2025[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Shri S.Rifaur Rahman

For Appellant: REVENUE BYFor Respondent: Date of Hearing

Section 115BSection 139Section 142(1)Section 147Section 148Section 69

Gautam Chopra, New Delhi vs. DCIT, Jhandewallan Extension

ITA 2567/DEL/2025[2021-2022]Status: DisposedITAT Delhi21 Jan 2026AY 2021-2022

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 69C

ease of M/s. DEEPAK BULDERS & ENGINEERS INDIA PVT. LTD. A search n/s 132 of Income Tax Act was conducted on an Entry operator Sanjay Jain along with his facilitators and some of his beneficiaries who were found to be generating cash against bogus billing of cement and other such items ... racketeers for inward communication and quick access. Sharing of a unique ID of pictures bank note serial numbers were utilized by the entry operators and the band of cash handlers and the recipients of the entries to mask the fraudulent transactions. 2. The beneficiaries have been found to have made

Aditi Infrabuild and Services Ltd., Delhi vs. DCIT, Central Circle-30, Delhi

ITA 5970/DEL/2024[2019-20]Status: DisposedITAT Delhi21 Jan 2026AY 2019-20

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 132Section 139(1)Section 153ASection 153CSection 153DSection 250Section 37

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "A" BENCH: NEW DELHI ITA No.5970/Del/2024 BEFORE SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER

ITO WD-3(1), Kolkata vs. Perfect Wahers & Fasteners (P) Ltd, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2599/KOL/2025[2015-16]Status: DisposedITAT Kolkata20 Jan 2026AY 2015-16

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

Section 144BSection 147Section 148Section 148ASection 68

total Income of Rs.1,34,100/-. An information was received by the AO that the appellant was identified as a beneficiary from search on entry operator Sanjiv Kumar Singh. Further the appellant had taken accommodation entry of Rs.10,00,000 from Shell entity M/s.Juhi Advisory Pvt Ltd. Based

ITO WD 3(1), Kolkata vs. Sapphire Global Finance Private Limited, Kolkata

In the result, all the three appeals of the Revenue are dismissed

ITA 1590/KOL/2025[2016-17]Status: DisposedITAT Kolkata20 Jan 2026AY 2016-17

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

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR

Section 133(6)Section 143(2)Section 148Section 148ASection 68

Upadhyaya & Shri jay Kumar Thakur was involved in accommodation entry providing and that they were layering funds through intermediaries i.e. shell companies managed by entry operators and M/s Khetan Tracon Pvt. Ltd. & M/s Prateek Plastimetals Pvt. Ltd. were the ultimate beneficiaries. Further, the AO also relies heavily on the statement

ITO WD-3(1), Kolkata vs. Sapphire Global Finance Private Limited, Kolkata

In the result, all the three appeals of the Revenue are dismissed

ITA 1506/KOL/2025[2015-16]Status: DisposedITAT Kolkata20 Jan 2026AY 2015-16

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

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR

Section 133(6)Section 143(2)Section 148Section 148ASection 68

ITO WD-3(1), Kolkata vs. Sapphire Global Finance (P) Ltd, Kolkata

In the result, all the three appeals of the Revenue are dismissed

ITA 1454/KOL/2025[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

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

Section 133(6)Section 143(2)Section 148Section 148ASection 68

Nitin Kaher, Delhi vs. Ward 44(6) Assessing Officer, Delhi

In the result, the Assessee’s appeal is partly allowed

ITA 5733/DEL/2025[2020-21]Status: DisposedITAT Delhi19 Jan 2026AY 2020-21

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2020-21 Nitin Kaher, Vs. Ao, Ward 44(6), F-21, Second Floor, Dsidc Delhi Complex, Udyog Nagar, Peera Garhi, Delhi – 110 041 (Pan: Aorpk8073N) (Appellant) (Respondent) Appellant By : Sh. R.K. Gaur, Ca Respondent By : Sh. Ajay Kumar Arora, Sr. Dr

For Appellant: Sh. R.K. Gaur, CAFor Respondent: Sh. Ajay Kumar Arora, Sr. DR

Section 144BSection 147Section 148Section 148ASection 37Section 37(1)Section 69C

plastic products and other allied goods. During search operation in one unrelated entity M/s Kapoor Watch Group, M/s Shri Govinda Enterprises was identified as entry operator. The assessee has made purchases from Shri Govinda Enterprises to the extent of Rs. 16,65,340/- out of total purchases made during

Atul Kumar Agrawal, Manpur Road, Kashipur vs. National E-Assessment Centre, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 19/DDN/2025[2018-19]Status: DisposedITAT Dehradun16 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year: 2018-19] Mr. Atul Kumar Agarwal Vs National Prop.M/S. R.K. Industries, E-Assessment Centre, Manpur Road, Kashipur, New Delhi U.S. Nagar, Uttarakhand- 244713 Pan-Aaopa9970H Appellant Respondent Assessee By Shri Deepak Joshi,Adv. & Shri Rudra Pratab, Adv. Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 13.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 04.12.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10235798 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income On 15.08.2018, Declaring Total Income At Inr 5,81,560/-. The Case Of The Assessee Was Re-Opened U/S 147 Of The Act. Accordingly, Notice U/S 148 Was Issued On 30.03.2022, In Response To Which The Assessee Filed Return Of Income On 03.05.2022, Declaring Same Income As Was Declared In The Return Filed U/S 139(1) Of The Act. Thereafter Notice U/S 143(2) Of The Act Was Issued Followed By Notices U/S 142(1) Alongwith Questionnaires. In Response Filed Replies From Time To Time. After Considering The Submissions Made By The Assessee, Ao Completed The Assessment Vide Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Wherein The Total Income Was Assessed At Inr 54,23,320/-.

Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69C

addition of alleged bogus purchases of Rs. 48,41,760/- u/s 69C which was made merely relying on the statement of the party (alleged entry operator), without making any independent enquiry or finding any corroborative evidence in this regard. 3. In the facts and circumstances of the case ... information received through High-Risk CRU that assessee has purchased goods from parties who either is entry provider or had purchased goods from entry operators however, no independent inquiry whatsoever was carried out by the AO before alleging so. Ld. AR further submits that once the books of accounts

Sudheer Chirania, Mumbai vs. The Income Tax Officer, Ward - 23(3)(7), Mumbai

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

ITA 5263/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Jan 2026AY 2012-13

Bench: Shri Saktijit Dey & Shri Jagadishassessment Year: 2012-13

For Appellant: Ms. Simran Dhawan & Mr. RaviFor Respondent: Shri Arun Kanti Datta, CIT DR

Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 68Section 69C

assessee, copies of the information relied upon and material seized by the department at the back of assessee, copies of statements of so-called entry operators recorded by investigation wing and also not allowing cross examination of such persons (who are departmental witnesses). Therefore, in our view some generic information

Horizon Buildmart Pvt Ltd, Gurgaon vs. ACIT, Circle-2, Faridabad

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

ITA 1250/DEL/2025[2011-12]Status: DisposedITAT Delhi16 Jan 2026AY 2011-12

Bench: Shri Sudhir Kumar & Shri Manish Agarwalhorizon Buildmart Pvt. Ltd., Asst. Cit, C-131, Ground Floor, Block-C, Central Circle-Ii, Sushant Shopping Arcade, Vs. Faridabad, Sushant Lok-1, Haryana-121001. Gurgaon-122002. Pan-Aacch4582P (Appellant) (Respondent) Shri S.S. Nagar, Ca Assessee By Department By Ms. Amisha S. Gupta, Cit Dr Date Of Hearing 03/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon (‘Ld. Cit(A)’ In Short) Dated 27.01.2025 In Appeal No.10581/Cit(A) Ggn-3/2018-19 For Assessment Year 2011-12 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (‘The Act’ For Short) Dated 28.12.2018. 2. Brief Facts Of The Case Are That Assessee Is Private Limited Company Engaged In The Business Of Real Estate. The Assessee Filed Its Return Of Income On 30.09.2011 Declaring A Loss Of Rs.54,833/-. The Ao Had Information That Assessee Received Loan Horizon Buildmart Pvt. Ltd. Vs. Acit

Section 143(2)Section 147Section 148Section 153C

respect of 'J' and 'N' and a large volume of documents were seized - It was revealed that assessee was major beneficiary of accommodation entry operations carried on by 'J' and ‘N’ - Assessing Officer, also received information from investigation wing that assessee had purchased penny scrips- Assessing Officer, based on information ... submits that by making inquiries, Investigation wing has already proved that the lender company is merely a paper company managed and controlled by some entry operators and thus the addition made should be sustained. 15. Heard both the parties and perused the materials available on record. In the instant case

Assistant Commissioner of Income Tax, New Delhi vs. Jalco Financial Services Private Limited, New Delhi

The appeal is dismissed

ITA 4209/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveenc Chandraacit, Vs. Jalco Financial Services Room No. 316A, C.R. Private Limited Building, I.P. Estate, K-7B, Ground Floor, New Delhi – 110002 Kalkaji, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacj2791E Appellant .. Respondent

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. Om Prakash, Sr. DR

Section 143(1)Section 143(3)Section 15HSection 37Section 37(1)Section 68

entries provided by lender company, M/s FairlinkCommotradePvt. Ltd. (FCPL) P a g e | 10 Jalco Financial Services Pvt. Ltd.(AY: 2017-18) through the entry operator Shri Vikas Kumar Agarwal. In other words, the said lender company, M/s FairlinkCommotradePvt. Ltd. (FCPL) is allegedly operated, controlled and managed by Shri Vikas ... fact, by bringing out any piece of evidence, that the lender company M/S FCPL was in any way connected, controlled and managed by entry operator Vikas Kumar Aggarwal as it was incumbent upon the AO to do so, because it was found that the sole basis of holding the appellant

ACIT, Circle-10(1), New Delhi vs. Index Securities & Research Pvt Ltd, New Delhi

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

ITA 2181/DEL/2022[2016-17]Status: DisposedITAT Delhi16 Jan 2026AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143(2)Section 250Section 68

Delhi. During the course of inquiry in the case of Shri Surendra Kumar Jain, it has been found that he is an entry operator and has provided accommodation entries to various entities including assessee company. Appellant Company was issued show-cause-notice dated 30.11.2018. No response was filed

Kameshwar Alloys and Steels Pvt. Ltd., Kolkata vs. ACIT, Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 49/RAN/2024[2014-15]Status: DisposedITAT Ranchi14 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

Section 131Section 132(1)Section 133(6)Section 133ASection 143(3)Section 144Section 153ASection 250Section 68

case of the revenue involving any investigation unit report or allegation pertaining to any bogus entity or statement of any entry operator or self rotation of cash. As a matter of fact, the share application money has been received from 9 companies, all of which is active even