9911796707
TMI Blog2023 (8) TMI 1305X X X X Extracts X X X X X X X X Extracts X X X X ..... appreciate that the Assessing Officer was made additions based on the information received from DDIT(Inv.)-II, New Delhi which was gathered after exercising search action u/s.132 in the residential and business premises of the alleged person Shri Surendra Kumar Jain and Shri Virendra Kumar Jain. 3. That the Ld. CIT(A) failed to appreciate that based on the incremental material found during search action and further enquiry after search, the above cited allegation of accommodation entries was established. 4. That the Ld. CIT(A) failed to appreciate that the submission made by the assessee (such as share application form, board resolution of the company, share receipt letter and confirmation, etc.) as proof for genuine transfer of money c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entities promoted and controlled by Shri Surendra Kumar Jain and Shri Virendra Kumar Jain of Delhi treating as unexplained money of the respondent-assessee of Rs. 1,90,00,000/-. The Assessing Officer also discussed the modus of operandi adopted by the respondent-assessee for receipt of share application money. 4. Being aggrieved by the order of assessment, an appeal was filed before the ld. CIT(A) contending that the Assessing Officer ought not to have made addition of Rs. 1,90,00,000/-, inasmuch as, the respondent-assessee had issued capital equity shares of Rs. 1,90,00,000/- and the amount had been received through the cheques. The respondent-assessee had discharged the initial onus of proving the identity, creditworthiness and genuinen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llegation of the Assessing Officer that share application money received is nothing but an unexplained income of the respondent-assessee routed through dummy entities floated by Shri Surendra Kumar Jain and Shri Virendra Kumar Jain of Delhi, who are known to be accommodation entries providers in the consideration of charging fees. 9. We heard the ld. Sr. DR and perused the material on record. The issue in the present appeal relates to the addition u/s 68 of Rs. 1,90,00,000/-. The Assessing Officer based on the information received from DDIT (Investigation)-II, New Delhi that the appellant is a beneficiary of the accommodation entries provided by Shri Surendra Kumar Jain and Shri Virendra Kumar Jain of Delhi through dummy entries promoted a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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