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ITAT dismissed the appeal and upheld the reopening of assessment, finding that the assessee operated as a conduit for accommodation entries rather than carrying on genuine business. The Tribunal concluded that large-volume credits and immediate onward transfers, effected by RTGS/cheque/transfer, lacked commercial rationale and constituted accommodation transactions executed for commission. In view of the assessee's failure to substantiate any delivery of goods or services or to explain the purpose of debit entries, the Tribunal sustained the tax authority's allegations and the resultant adjustments arising from the information received from DDIT(Inv.), treating the receipts as non-business, sham transactions and affirming the assessment re-opening and consequent additions.
ITAT dismissed the appeal and upheld the reopening of assessment, finding that the assessee operated as a conduit for accommodation entries rather than carrying on genuine business. The Tribunal concluded that large-volume credits and immediate onward transfers, effected by RTGS/cheque/transfer, lacked commercial rationale and constituted accommodation transactions executed for commission. In view of the assessee's failure to substantiate any delivery of goods or services or to explain the purpose of debit entries, the Tribunal sustained the tax authority's allegations and the resultant adjustments arising from the information received from DDIT(Inv.), treating the receipts as non-business, sham transactions and affirming the assessment re-opening and consequent additions.
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