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2023 (8) TMI 881 - AT - Income TaxReopening of assessment u/s 147 - assessee is one of the beneficiaries of the accommodation entries receipt by entity - plea of the AR that the reassessment proceedings have been initiated entirely based on the satisfaction borrowed from the Investigation Wing and no independent inquiry was conducted by the assessee to come to the aforesaid conclusion - HELD THAT:- As on the basis of information received from the investigation wing, reassessment proceedings in the case of the assessee were initiated. As also well settled that sufficiency or correctness of the material is not a thing to be considered at the stage of recording the reasons. As a result, we find no infirmity in the reassessment proceedings initiated by the AO u/s 147 of the Act. Accordingly, ground no. 1 in assessee’s appeal, raised as an additional ground, is dismissed. Addition u/s 68 - As evident from the record, the Revenue has doubted the existence of this entity and has claimed that this entity to be only a paper entity that works to issue accommodation entries. The aforesaid documents prove to the contrary as not only details of the loan by Bhoomidevi Credit Corporation Ltd. to the assessee is recorded in the financial statements of the aforesaid entity, similar details are corroborated from the ledger account of Bhoomidevi Credit Corporation Ltd. in assessee’s books. Since the assessee has proved the existence of Bhoomidevi Credit Corporation Ltd., we find no merits in the findings of AO which were upheld by the learned CIT(A). Accordingly, the addition made by the AO and upheld by the learned CIT(A) is deleted and grounds raised by the assessee on merits are allowed.
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