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The HC affirmed the lower appellate authorities' findings that the Assessee was a mere conduit for routing accommodation entries. The unexplained credits were determined to be taxable in the hands of ultimate beneficiaries, not the Assessee. No commission income was established for the Assessee, as the Jain Brothers were identified as the actual accommodation entry operators. The court noted minimal variations in bank account balances, supporting the conclusion that the Assessee was used as a pass-through entity. Consequently, no substantial questions of law were found, and the appeal was dismissed.
The HC affirmed the lower appellate authorities' findings that the Assessee was a mere conduit for routing accommodation entries. The unexplained credits were determined to be taxable in the hands of ultimate beneficiaries, not the Assessee. No commission income was established for the Assessee, as the Jain Brothers were identified as the actual accommodation entry operators. The court noted minimal variations in bank account balances, supporting the conclusion that the Assessee was used as a pass-through entity. Consequently, no substantial questions of law were found, and the appeal was dismissed.
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