M/S. SUPER SHIV SHAKTI MINCHEM PVT. LTD.,JODHPUR vs. ITO, WARD-3, , BHILWARA
In the result, both the above appeals filed by the Assessee are dismissed
ITA 21/JODH/2018[2009-10]Status: DisposedITAT Jodhpur17 Jun 2025AY 2009-10
Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)
For Appellant: Shri Goutam Chand Baid, C.AFor Respondent: Shri Karni Dan, Addl. CIT (Sr. D.R)
Section 147Section 148Section 6Section 68Section 69C
section 68 if the overall transaction lacks credibility and commercial rationale. The onus is higher where entities are found to be part of an accommodation entry racket, and in such circumstances, the test of human probability must prevail over formality.
14. The assessee has placed on record a set of documents in support of the receipt of share capital